Insight 01
CSRD after Omnibus: A Current Picture for Turkish Companies
- Topic
- Sustainability Reporting
- Type
- Regulatory note
- Date
- 2026-Q2
- Author
- Solo Institute
Insight 01Summary
The EU's Corporate Sustainability Reporting Directive (CSRD) entered into force in 2024 — but the form in which it entered is not the form it has today.
In February 2025 the European Commission proposed the Omnibus I Simplification Package; in April 2025 the "Stop-the-Clock" directive (2025/794) was adopted, deferring waves 2 and 3 by two years.
In this note we discuss the reasonable first move for Turkish companies under the current timeline and the uncertainties still in negotiation.
Key points
- Post-Stop-the-Clock timetable: Wave 1 (large listed) unchanged; Wave 2 (large non-listed) FY2025 → FY2027; Wave 3 (listed SMEs) FY2026 → FY2028; third-country (€150M+ EU turnover) still under negotiation.
- Postponement is not cancellation. The EU has not changed direction on ESG — only the speed has slowed. Investor, lender and large-buyer expectation is where it was.
- Omnibus uncertainty is not deferred preparation. ESRS simplification may reduce the number of data points, but double materiality remains the core discipline.
Section 1 — What did Stop-the-Clock and Omnibus I change?
Directive 2025/794 ("Stop-the-Clock"): the first concrete output of Omnibus I (February 2025), adopted in April 2025. It does three things: defers waves 2 and 3, delays CSDDD application by one year, and leaves wave 1 unchanged.
Omnibus I substantive proposals: in parallel, the Commission has proposed reviewing ESRS standards and CSRD scope thresholds — fewer data points, higher "large company" thresholds, deferred sector standards. Final text expected mid-2026.
For third-country companies (including Turkish holdings): the original 2028 target is unchanged for now, but Omnibus I's final content may affect third-country scope.
Section 2 — ESRS Architecture
ESRS consists of two cross-cutting standards and ten thematic ones: ESRS 1 (general requirements, double materiality methodology), ESRS 2 (general disclosures), Environmental (E1–E5), Social (S1–S4), Governance (G1).
Double materiality is ESRS's core discipline: a topic is reported if either (a) the organisation's impact on environment and people, or (b) the world's effect on the organisation's financial position crosses the threshold.
Section 3 — The First Six Months for Turkish Companies
- Materiality workshop (double: impact + financial)
- Gap analysis (what data exist, what process is missing)
- KPI system design (mapped to ESRS disclosure requirements)
- Pilot report production (using the previous fiscal year's data)
- Dialogue with assurance providers (Big-Four)
- Board briefing (CSRD is not just a compliance task — change must be owned)
Section 4 — Common Mistakes
- "It was postponed, we can wait"
- Omnibus content is still in negotiation; even if scope shifts, materiality discipline persists
- "We'll adapt our previous sustainability report"
- ESRS structure differs from GRI; not a direct conversion
- "We'll outsource the materiality study to an agency"
- ESRS cannot be validated without internal stakeholder participation
- "We'll do data last"
- Data systems take 6–12 months; a late start cannot be assured
Conclusion
Stop-the-Clock is a breathing moment, not a signal of retreat. EU regulation has not changed direction — only the pace has dropped. If this period is spent on double materiality discipline and data system set-up, the report will be produced without strain when it is required. Whatever happens, large Turkish companies' need to speak the ESG language to investors and large customers is already inevitable.
Editor's note
Omnibus I negotiation is ongoing. This note reflects the 2026-Q2 state; it will be updated once the EU Council-Parliament agreement lands.
Solo Institute runs the full path for Turkish companies completing the CSRD transition — from materiality workshop to independent assurance readiness.