Environmental, Social and Governance (ESG) Law

The framework that binds companies today

In Türkiye, the Turkish Sustainability Reporting Standards (TSRS) published by the Public Oversight, Accounting and Auditing Standards Authority have made reporting mandatory for undertakings that exceed the prescribed thresholds and, regardless of size, for banks, insurance companies and publicly held corporations brought within scope. The obligation rests on the Turkish Commercial Code, and non-compliance is subject to an administrative fine. Climate Law No. 7552 and the Turkish Emissions Trading System legislation issued under it have turned greenhouse-gas emissions into a direct cost and liability item, through the emission permit, the allowance and the obligation to surrender allowances.

On the European Union side, the Corporate Sustainability Reporting Directive and the Corporate Sustainability Due Diligence Directive remain in force, although a 2026 simplification measure narrowed their scope. Most Turkish companies are not direct addressees of these directives; to the extent they supply in-scope European buyers, however, they encounter the same obligations as contractual terms. The Carbon Border Adjustment Mechanism, the regulation on preventing deforestation and other product-based instruments have also ceased, for exporters, to be a matter of reporting and have become a condition of market access.

The practical result is this: ESG obligations no longer bind only the large companies in scope, but also the medium-sized businesses that supply them with goods and services.

Our services

• Scope and obligation analysis. Determining the company’s position against the TSRS, EU legislation and sectoral rules; setting out, as a legal opinion, which obligation arises from which date, who is responsible, and what the consequences of non-compliance are.
• Sustainability reporting and public disclosure. Legal review of reports, checking that statements conform to the legislation and to the company’s actual position, and legal support during the assurance engagement.
• Climate and carbon. Emission-permit applications, management of allowance obligations, carbon-market transactions, structuring export processes within the Carbon Border Adjustment Mechanism, and applications against administrative sanctions.
• Supply chain and contract management. Negotiation of ESG commitment, audit, information and termination clauses received from buyers; redrafting supplier contracts so that they pass these obligations on; preparing supplier codes of conduct and audit protocols.
• Sustainable finance. Documentation for green bonds, sustainability-linked loans and similar instruments, reflecting performance indicators in the contract, and managing events of breach.
• Corporate governance. Defining sustainability responsibility at board level, committee design, allocation of duties, establishing the flow of information, and determining the limits of directors’ legal liability.
• Policies and internal rules. Preparing codes of ethics, whistleblowing mechanisms, and human-rights and environmental policies, and operating these mechanisms in line with personal-data legislation.
• Internal investigations. Examining allegations arising from sustainability commitments, supplier audits or reports, and setting the legal roadmap according to the outcome of the investigation.
• Greenwashing risk. Assessing environmental claims in advertising, labelling and corporate-communications materials under consumer-protection and unfair-competition law.
• Transactions and disputes. ESG-focused legal review in mergers and acquisitions and reflecting it in the transaction documents; challenges to administrative sanctions, actions for annulment, and pursuit of contractual disputes.

How we work

ESG does not fit inside a single specialism. An emissions obligation concerns environmental, administrative and criminal law at once; a supplier-audit clause concerns commercial, employment and data-protection law; a sustainability cooperation concerns competition law. As a firm that practises across the law, FIOR handles these matters without splitting them apart, through a single team in which lawyers from the relevant fields work together.

Our long experience in export-intensive sectors, above all automotive, manufacturing, energy, retail and finance, gives us a practical view particularly where obligations originating in the European Union reach Turkish companies through the supply chain. Through the lawyers working in our offices in London, Germany and Canada as well as Istanbul, we can assess cross-border obligations together with the legal order in which they originate.

You may contact us to clarify where you stand against your sustainability obligations and to plan the timetable ahead.