What is CSRD?
The Corporate Sustainability Reporting Directive (CSRD — Directive (EU) 2022/2464) is the EU’s framework for mandatory sustainability reporting by companies, replacing and dramatically expanding the 2014 Non-Financial Reporting Directive (NFRD). CSRD requires reporting in line with European Sustainability Reporting Standards (ESRS), with double materiality, third-party assurance, and machine-readable filing. Phased entry: first reports (covering FY2024) from large public-interest entities published in 2025.
Who is in scope (phased)
- FY2024 (reported 2025): large public-interest entities (500+ employees) already under NFRD.
- FY2025 (reported 2026): all other large EU companies meeting 2 of: >250 employees, >€50M turnover, >€25M balance sheet.
- FY2026 (reported 2027): listed SMEs (with opt-out until 2028).
- FY2028 (reported 2029): non-EU companies with >€150M EU turnover and EU subsidiary/branch meeting thresholds.
ESRS — what gets reported
- ESRS 1: general requirements (materiality, value chain).
- ESRS 2: general disclosures (strategy, governance, risk).
- Environment (E1-E5): climate change, pollution, water, biodiversity, circular economy.
- Social (S1-S4): own workforce, workers in value chain, affected communities, consumers/end users.
- Governance (G1): business conduct.
Double materiality
Companies must report on both impact materiality (the company’s effect on people and environment) and financial materiality (sustainability risks affecting the company’s value) — broader than US-style financial materiality.
CSRD exposure for Turkish groups
CSRD reaches Turkish companies along three vectors: EU subsidiaries above size thresholds report locally; large groups with significant EU turnover face the third-country regime; and — most commonly today — Turkish suppliers receive data requests because their EU customers must report value-chain information. Parallel to this, KGK’s TSRS regime imposes ISSB-based reporting domestically above defined thresholds. The efficient response is one sustainability-data architecture serving both: a single emissions and workforce data model, one materiality assessment with CSRD’s double-materiality lens, consistent narratives across TSRS reports, customer questionnaires and investor decks. Inconsistency between these surfaces is the cheapest finding a greenwashing reviewer or M&A diligence team can collect.