A framework of defensible disclosure in sustainability reporting.
The legal framework for reporting and data requests arising from CSRD/ESRS: double materiality, value-chain data, customer questionnaires, and the legal risks of disclosures.
Why is reporting a legal matter?
CSRD has made the sustainability report an audited part of the management report. This means that every disclosure can carry legal consequences: an overstated climate target can turn into a greenwashing allegation, an incomplete value-chain disclosure into an audit finding, and a wrong answer in a supplier questionnaire into a breach of contract. Reporting is now on the desk not only of the sustainability team but also of the legal function.
Two scenarios for Turkish companies
Indirect scope (today's reality): Your EU customers ask you for emissions, energy, occupational health and safety, and human rights data for their own reports. The contractual basis of these requests, the limits of data sharing, and the protection of trade secrets can be negotiated — and should be. Direct scope (tomorrow's possibility): Turkish groups with significant turnover and subsidiaries in the EU may become directly subject to reporting under the phased timeline; preparation must begin at least one full financial year in advance.
Double materiality and data infrastructure
The double materiality analysis at the heart of ESRS — the company's impact on the environment/society and the impact of sustainability risks on the company — must be documented with legal rigor, because the rationale for what will not be reported is also audited. Assigning responsibility in data-collection processes, documenting sources and building shared infrastructure with the LkSG programme prevent duplicated effort.
A five-step reporting programme
Scope and timetable analysis: against Directive (EU) 2022/2464 and the current changes to the timetable, we establish which wave you fall into and in what role. Gap analysis: your existing data and policy infrastructure is measured against the ESRS data points. Contract filter: the reporting commitments in customer questionnaires and supply contracts are brought under a single standard. Sign-off: a pre-publication legal clearance step is put in place, and marketing claims are tested for consistency with the language of the report. Monitoring: an annual update cycle. Deliverables: a scope report, a data-governance chart and a disclosure checklist, with the programme running under our compliance services.
TSRS: reporting is no longer an EU-only agenda
The Türkiye Sustainability Reporting Standards (TSRS 1 and TSRS 2), published by the Public Oversight Authority (KGK), have started the mandatory reporting period for Turkish companies above the defined thresholds. For a group already preparing for the CSRD this is an advantage: double materiality, data collection and internal control are built once and answer to both frameworks. The service is used most often by manufacturers supplying German OEMs, listed groups and exporters with EU customers. The supply-chain side is handled by our ESG & Supply Chain Desk.
We are by your side for CSRD & Sustainability Reporting
We begin with a scope and timeline analysis (after stop-the-clock, which wave are you in?), establish a legal filter for customer questionnaire and contract requests, add a “legal sign-off” step to the disclosure approval process, and audit marketing-report consistency against greenwashing risk. As part of our ESG focus, we combine reporting with your due diligence programme into a single strategy.
Other Applications of This Service
Compliance — our other specialised solutions in this area.
Matter Connections
The focus areas, practice areas, desks and legislation connected with this sub-service.
Our Matters in This Service
The anonymised examples of our work that relate to this service.
Uninterrupted legal counsel for a multinational supplier
Retainer-based support across day-to-day commercial operations, contract management and compliance processes.
Review the matter →ESG & ComplianceSupply chain due diligence (LkSG) compliance programme
Risk assessment and compliance architecture for a Turkish supplier network under the German LkSG.
Review the matter →Market AccessEstablishing a distribution network in Türkiye
Designing a market entry strategy, distributorship agreements and competition compliance.
Review the matter →The Team Delivering This Service
With our multilingual team of lawyers, well-versed in Turkish and German law, we are by your side.
Mehmet Köksal
Founder and Managing PartnerIstanbul · Berlin · KyreniaProfile →
Kübra Köksal-Yılmaz
PartnerBerlin · İstanbulProfile →
Gül Efem
Of CounselİstanbulProfile →
Sven Köksal
Legal EngineerBerlin · İstanbulProfile →
Gökçe Yıldırım
Of CounselİstanbulProfile →Related Publications
Fresh perspectives and guides from the Knowledge Centre.
Sustainability claims on your website and in your reports can serve as the basis for consumer law, unfair competition, and investor claims. We compile an inventory of your claims and correct statements that cannot be substantiated.
CSRD reports are subject to limited assurance, and a transition to reasonable assurance over time is under discussion. The legal consistency of the evidence file to be presented to the auditor is part of the preparation.
The first wave (large listed companies already within the scope of the NFRD) has been reporting since financial year 2024; the subsequent waves were postponed by two years under the “stop-the-clock” directive, and the thresholds are being debated in the simplification package.…
The obligation depends on your contract. Data requests are legitimate, but the scope, format, and confidentiality limits can be negotiated; protective mechanisms should be put in place for process data that qualifies as a trade secret.
CSRD & Sustainability Reporting — get the right legal support.
Let us identify the right solution together, drawing on our experience in Türkiye and the DACH region.