Policy Brief: The First 100 Days of TSRS Compliance

The Türkiye Sustainability Reporting Standards (TSRS) open the door to a new era in which companies are required to publicly disclose their environmental, social, and governance (ESG) performance. This new framework is not merely about regulatory compliance; it also marks a turning point for strategic management, investor relations, and corporate transformation.

This policy brief aims to provide a simplified roadmap for planning TSRS-related obligations within the first 100 days. Our target audience includes companies subject to TSRS for the first time and managers unsure of where to start the compliance process.

Why Are the First 100 Days Critical?

• Need for retrospective data: TSRS requires companies to present not only current-year but also comparative data from the previous year. Therefore, every delayed day makes compliance harder and increases the effort to reconstruct past ESG records.
• Need for comprehensive analysis: TSRS examines not only emissions but also workforce structure, supply chain, gender balance, and governance framework. A cross-functional and enterprise-wide approach is required.
• Board of Directors accountability: TSRS compliance is not solely the responsibility of the sustainability department—it directly involves senior management and the board of directors. Board-level clarity on ESG terminology and risks is essential.

Five-Phase Strategy for the First 100 Days of TSRS

1. Current State Inventory (Days 1–20)

• List all ESG data currently collected.
• Review past reports based on GRI or ESRS, if available.
• Identify employees involved in ESG-related functions within the current organizational structure.
• Tip: Existing certifications (ISO 14001, 50001, SA8000) can be integrated into this process.

2. Data Gap Analysis (Days 21–40)

• Identify areas where data is lacking (e.g., Scope 3 emissions).
• Note shortcomings especially in social indicators (e.g., female employment, unionization, employee satisfaction).
• Consider stakeholder interviews or surveys as data collection tools.
• Tip: Focus on “why these indicators matter” instead of simply “filling in the blanks.”

3. Terminology Mapping and Alignment (Days 41–60)

• Define terms like “double materiality,” “significant impact,” and “financial materiality” (also referred to as “financial relevance”) in the company’s specific context.
• Clarify these terms at the board level to ensure shared understanding.
• External consultancy support is valuable at this stage.
• Tip: Create a comparison table to align potentially conflicting terms between TSRS and ESRS and identify conceptual mismatches.

4. Data Collection and Indicator Preparation (Days 61–90)

• Identify internal and external data sources for targeted indicators.
• Define procedures for data accuracy and continuity (who, when, how?).
• Assign data stewards (or owners) and create a reporting timeline.
• Tip: A responsibility matrix and internal communication cycle (or loop) help strengthen institutional memory.

5. Draft Report and Board Presentation (Days 91–100)

• Prepare the first draft report in accordance with TSRS.
• Clearly present risks, opportunities, and strategic priorities.
• Conduct final review with the board of directors and relevant departments.
• Tip: The draft report can serve as a foundational document not only for compliance but also for investor communication.

Conclusion

TSRS compliance is a complex but manageable process. The key is to treat it not as a “burden” but as a “transformation opportunity.” The first 100 days are a unique window for laying the foundation of this transformation.

Remember: TSRS compliance is not just about “what you know,” but “why and how you report it.”