Executive Summary
2026 will be a landmark year for corporate sustainability compliance. The CBAM definitive phase, CSRD second-wave reporting, TR-ETS pilot preparations, and expanded TSRS requirements are all coming into effect simultaneously. This report presents all major compliance deadlines, preparation requirements, and prioritization strategy.
Critical Date Summary
| Date | Event | Impact |
|---|---|---|
| January 1, 2026 | CBAM definitive phase begins | Certificate purchase obligation |
| Q1 2026 | CSRD wave 1 first reports published | Value chain data requests increase |
| Q1-Q2 2026 | TSRS second reporting year begins | Scope expands |
| H1 2026 | TR-ETS pilot period preparations | MRV infrastructure required |
| July 2026 | CDP 2026 questionnaire deadline | Annual disclosure cycle |
| H2 2026 | CSRD wave 2 preparation period | FY 2025 reporting planned |
| December 2026 | SBTi commitment period review | 24-month validation window |
CBAM: The Definitive Phase Begins
What's Changing?
As of January 1, 2026, the transition from CBAM's transitional to definitive phase is complete. Importers must now purchase CBAM certificates corresponding to embedded emissions (Regulation 2023/956, Article 7).
Certificate prices are linked to the weekly average of EU ETS allowance prices. As of late 2025, EU ETS prices are in the EUR 60-80/tCO2 range. At EUR 72/tCO2 — a reasonable mid-range estimate — the annual CBAM cost exposure for Turkish industry is substantial: approximately EUR 400-600 million for the steel sector and EUR 80-130 million for cement, depending on export volumes and emission intensities.
Who Is Affected?
All Turkish companies exporting steel, aluminium, cement, fertilisers, electricity, and hydrogen to the EU. Turkey is the third-largest source of EU steel imports and the second-largest source of cement imports, making the country one of the most CBAM-exposed trading partners globally.
The Data Advantage
The most immediate lever for reducing CBAM costs is not decarbonization — it is data quality. Commission default values are set above sector averages, meaning companies that provide verified actual facility data typically pay 15-40 percent less than those relying on defaults. For a Turkish EAF steel producer, the difference between actual data (~0.5 tCO2/tonne) and default values (~1.3 tCO2/tonne) amounts to roughly EUR 60 per tonne at current EU ETS prices (JRC, 2023). Over 100,000 tonnes of annual exports, this represents EUR 6 million in avoidable costs.
Action Items
- Prepare verified facility-level emissions data for all CBAM-covered products
- Contract with an accredited verifier (capacity is limited — move early)
- Reflect CBAM financial impact in your 2026 operating budget
- Monitor TR-ETS carbon price deduction opportunity — once operational, every Euro paid in Turkey reduces CBAM costs
- Standardize a data package template for EU importers (facility emissions, production volumes, specific emissions per tonne)
CSRD: Wave 2 Preparation
2026 Timeline
In CSRD's phased implementation:
- Wave 1 (large PIEs, 500+ employees): Published FY 2024 reports in H1 2025. First-wave reports are now public, providing templates and benchmarks for wave 2 companies.
- Wave 2 (all large companies meeting 2-of-3 criteria: 250+ employees, EUR 50M turnover, EUR 25M assets): Will report for FY 2025, with reports published in H1 2026.
This expansion brings approximately 11,000 additional EU companies into direct scope (European Commission, 2021) — and indirectly affects hundreds of thousands of suppliers through value chain data requests (Directive 2022/2464, Article 5).
Implications for Turkish Suppliers
Data requests from EU customers will increase significantly in 2026 as wave 2 companies begin their first data collection cycles. The requests will cover:
- Environmental: GHG emissions (Scope 1, 2, and increasingly Scope 3), energy consumption, water withdrawal, waste generation
- Social: Occupational health and safety metrics, workforce diversity data, training hours
- Governance: Human rights policies, anti-corruption measures, supply chain due diligence
EFRAG's implementation guidance provides transitional provisions for SME suppliers, but the data requests themselves are not optional — they are a prerequisite for EU companies' own ESRS compliance (EFRAG Implementation Guidance IG 2, 2023).
Action Items
- Complete your double materiality assessment if you are in EU supply chains — this determines which data you need to collect
- Design standardized processes to respond to customer data requests — a template response covers most CSRD-driven queries
- Prepare an ESRS-to-TSRS mapping table — for companies subject to both, this avoids duplicate data collection
- Anticipate CSRD Article 40: Turkish groups with EUR 150M+ EU revenue may fall directly under CSRD from FY 2028
SBTi: The Validation Window
SBTi Expectations in 2026
Companies that have committed to SBTi must submit their targets for validation within 24 months of commitment. For companies that committed in 2024, the end of 2026 is a critical threshold — failure to submit within the window means the commitment lapses and must be restarted (SBTi Corporate Manual, 2023).
As of 2025, over 7,000 companies globally have committed to or validated science-based targets. The wave is reaching Turkey: an increasing number of Turkish companies — driven by EU customer expectations, investor pressure, and TSRS alignment — are entering the SBTi pipeline. The validation process typically takes 12-18 months from commitment to approval, meaning companies committing in H1 2026 need to begin target development immediately.
The Scope 3 Challenge
For most companies, the SBTi validation bottleneck is Scope 3 data. If Scope 3 represents more than 40 percent of your total emissions (which it does for the vast majority of companies), you must set a Scope 3 target. This requires a comprehensive Scope 3 screening across all 15 categories and reliable data for the material categories.
The good news: Scope 3 data collected for SBTi validation feeds directly into TSRS reporting, CSRD data requests, and CDP disclosure. The investment in Scope 3 data pays dividends across multiple compliance obligations.
Action Items
- Check your commitment date and calculate remaining time — if less than 12 months remain, begin target development immediately
- Complete your Scope 3 emissions inventory using the GHG Protocol Scope 3 Standard
- Choose your target pathway (Sectoral Decarbonization Approach or absolute contraction)
- Calculate targets and submit for validation
- Begin annual progress reporting via CDP
TSRS: Second Reporting Year
KGK's TSRS requirements became mandatory for FY 2024, making 2025 the second reporting year. In the second year:
- Comparative data presentation expected (against previous year)
- More detailed Scope 3 disclosure
- Some transitional reliefs expiring
Evaluating SPK's sustainability communique alongside TSRS is an efficient approach (KGK, 2023; SPK, 2024).
TR-ETS: Pilot Period Approaching
Under Climate Law 7552, the TR-ETS pilot period is planned to begin in 2026. Preparations with World Bank technical support are prioritizing MRV infrastructure establishment (World Bank, 2024).
Action Items
- Establish or strengthen MRV infrastructure
- Prepare facility-level emissions monitoring plans
- Compare your emission intensity with EU ETS benchmark values
CDP 2026 Cycle
CDP's annual disclosure cycle runs from February to July. The 2026 questionnaire is further aligned with ISSB (CDP, 2024).
Prioritization Matrix
High Urgency + High Impact
- CBAM definitive phase preparation (certificate costs have started)
- CSRD value chain data requests (customer relationship risk)
High Impact + Medium Urgency
- SBTi validation timeline (24-month window)
- TSRS second-year improvements
Medium Urgency + Strategic Value
- TR-ETS pilot preparation (CBAM cost advantage)
- CDP 2026 questionnaire (supply chain program)
The Cross-Framework Advantage: Build Once, Comply Many
The number of frameworks may seem overwhelming, but the underlying data requirements overlap significantly. A single, well-structured data collection infrastructure can feed CBAM reporting, TSRS/ISSB compliance, CSRD data requests, CDP questionnaires, and SBTi validation:
| Data Point | CBAM | TSRS | CSRD | CDP | SBTi |
|---|---|---|---|---|---|
| Scope 1 emissions | Yes | Yes | Yes | Yes | Yes |
| Scope 2 emissions | Yes (some products) | Yes | Yes | Yes | Yes |
| Scope 3 emissions | No | Yes | Yes | Yes | Yes |
| Energy consumption | Indirect | Yes | Yes | Yes | Yes |
| Emission reduction targets | No | Yes | Yes | Yes | Yes |
| Governance structure | No | Yes | Yes | Yes | No |
| Transition plan | No | Yes | Yes | Yes | No |
The company that builds one robust GHG inventory, establishes one governance structure, and sets one science-based target has effectively addressed the data requirements of all five frameworks. The company that treats each framework as a separate project will spend five times the effort for the same outcome.
Conclusion
2026 is the year sustainability compliance becomes an operational necessity — not a corporate communications exercise. The convergence of CBAM financial obligations, CSRD reporting requirements, SBTi validation windows, and emerging TR-ETS infrastructure creates a compliance density that cannot be managed reactively.
The companies that will navigate 2026 successfully share three characteristics: they have invested in data infrastructure before it became mandatory, they treat multiple frameworks as one integrated process rather than separate projects, and they have executive-level ownership of the compliance strategy.
For Turkish enterprises, 2026 also carries a strategic dimension that goes beyond compliance: TR-ETS development, CBAM cost deduction potential, and the ability to demonstrate ESG credentials to international customers and investors. Companies that build compliance capacity now are not just avoiding penalties — they are positioning for competitive advantage in a market where sustainability performance increasingly drives commercial relationships.