ESG Regulation in the European Union and Türkiye: A Comparative Analysis under the CSRD, ESRS, and TSRS Frameworks

Abstract

Binding reporting and due diligence duties have increasingly shaped environmental, social, and governance (ESG)-oriented corporate accountability as climate-related risks have become more visible within the financial system. This study examines the normative architecture of ESG regulation in the European Union (EU) through the Corporate Sustainability Reporting Directive (CSRD), the European Sustainability Reporting Standards (ESRS), and the Corporate Sustainability Due Diligence Directive (CSDDD), and offers a comparative assessment with the Türkiye Sustainability Reporting Standards (TSRS) and the sustainability principles regime of the Capital Markets Board of Türkiye (CMBT). A qualitative, doctrinal, and comparative legal research design is employed. The comparison is structured around scope and application thresholds, materiality logic, assurance and enforcement design, and value-chain reach. Primary sources consist of EU directives, regulations, delegated acts, and official implementation materials, together with Turkish standards, board decisions, and regulatory texts, complemented by selected peer-reviewed scholarship. The analysis finds that the EU model is designed as a layered framework linking standardized sustainability disclosure, external assurance, digital reporting, and a double materiality logic with process-based due diligence obligations across the value chain. The CSRD/ESRS package is shown to turn sustainability statements into auditable corporate disclosures integrated into governance, strategy, and risk management narratives, while the CSDDD shifts the regulatory focus from disclosure to prevention through mandatory policies, monitoring, remediation mechanisms, and climate transition planning. In Türkiye, TSRS is identified as an ISSB-aligned, financial materiality-oriented reporting framework, whereas the CMBT principles promote disclosure through a comply-or-explain approach. The comparison indicates that firms engaged with EU markets are likely to face a dual compliance challenge: some governance, strategy, risk-management, and climate disclosures can be aligned across TSRS and ESRS, whereas impact materiality, taxonomy reporting, and value-chain due diligence remain distinctly EU-specific. Future research is recommended to map enforcement practices and to evaluate disclosure quality and litigation exposure empirically.