Gulers Partners
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III - THE LEGAL AND COMMERCIAL IMPORTANCE OF CARBON REPORTING STANDARDS FOR COMPANIES

1. Introduction: The Role of Standardization in Carbon Reporting The rapid development of regulatory frameworks aimed at combating climate change on a global scale has fundamentally transformed how companies manage their environmental impacts. Today, companies are expected not only to measure their greenhouse gas emissions but also to present this data using internationally recognized, comparable, and verifiable methodologies. Particularly for companies operating in Türkiye and engaged in international trade, carbon reporting obligations are becoming increasingly decisive. In particular, the European Union Green Deal, the Carbon Border Adjustment Mechanism (CBAM), and sustainable finance regulations have effectively rendered the presentation of carbon data through non-standard methods obsolete. Within this framework, carbon reporting has evolved from being merely an environmental obligation into a determining factor for commercial continuity, access to finance, and international competitiveness. This transformation elevates carbon management from a technical activity to a core component of compliance, risk management, and corporate governance.

Avukat Mustafa Tansu GÜLER
April 8, 2026

2. What is the TS EN ISO 14064-1:2019 Standard?

The TS EN ISO 14064-1:2019 standard provides an international framework that enables organizations to manage their greenhouse gas emissions and removals at the organizational level in a systematic, consistent, and auditable manner.

This standard ensures that carbon data are:

  • Calculated based on defined methodologies,
  • Recorded,
  • Reported,
  • Subject, where necessary, to independent verification.

By doing so, it renders companies’ environmental disclosures reliable and legally meaningful. In this respect, ISO 14064-1 transforms the carbon footprint from a purely technical dataset into a corporate disclosure system that is taken into account by regulators, investors, and commercial stakeholders.

3. Core Structure of the Standard

The TS EN ISO 14064-1 standard addresses carbon management within a holistic system built upon three main pillars. This structure aims to ensure that companies both correctly define their areas of responsibility and guarantee the reliability of the data they produce.

a) Determination of Organizational Boundaries

The first step under the standard is to determine which of the company’s activities will be included in the carbon inventory. Approaches such as operational control, financial control, or equity share may be adopted in this process.

This determination is not merely a technical scoping exercise; it also defines the legal boundaries of the emissions for which the company will be held responsible. This distinction is particularly critical for group companies and joint ventures in terms of allocating responsibility.

b) Definition of Reporting Boundaries

Once organizational boundaries are determined, the types of emissions to be reported within this scope are identified. In addition to direct emissions, the inclusion of energy-related and other indirect emissions may significantly expand the company’s carbon responsibility.

This approach leads to companies being assessed not only for their own operations but also for impacts arising throughout the entire value chain. Therefore, accurately defining the reporting scope is a critical stage both for regulatory compliance and for preventing the risk of misleading disclosures.

c) Calculation, Monitoring, and Reporting Process

The standard also regulates in detail the processes for generating carbon data. The collection of activity data, the use of appropriate emission factors, and the calculation of results in CO₂ equivalent form the core elements of this process.

However, the key aspect lies in managing these data within a transparent, consistent, and traceable system. This structure ensures that carbon reports are open to independent verification while also enabling companies to present their data with confidence during audits and inspections.

4. Which Companies Is It Critical For?

The TS EN ISO 14064-1 standard is particularly critical for companies operating in carbon-intensive sectors and those engaged in international trade.

Companies in sectors such as energy, cement, iron and steel, and chemicals are among those for whom compliance with this standard has effectively become mandatory due to direct regulatory exposure.

Moreover, for companies with commercial relations with the European Union, presenting carbon data in accordance with standards has become a prerequisite for market access.

For large-scale companies and corporate entities, carbon reporting is also a decisive factor in investor relations and access to finance. Meanwhile, SMEs involved in supply chains are increasingly required to comply indirectly with this standard in line with the demands of larger companies.

In this context, carbon management has evolved into a shared responsibility across the entire value chain, rather than being limited to specific sectors.

5. Legal Implications: More Than a Standard

In practice, the TS EN ISO 14064-1 standard goes beyond being a technical guideline and establishes a framework that produces direct legal consequences for companies.

a) Reporting Obligations and Compliance

Accurate and complete reporting of carbon data constitutes an increasingly stringent compliance obligation. Incorrect or incomplete disclosures may lead not only to administrative sanctions but also to contractual liability and reputational damage.

Therefore, carbon reporting should be treated as an active area of risk management for companies.

b) Auditability and Verification

The standard provides for the examination of carbon data by independent verifiers, ensuring that such data are objectively tested. This transforms carbon reports from internal documents into datasets that may be subject to legal scrutiny by external stakeholders.

c) Board of Directors’ Responsibility

Carbon management has become part of the responsibility of companies’ top management bodies. Boards of directors are expected to foresee carbon-related risks and establish accurate reporting systems.

Failure to fulfill this obligation may result in liability for breach of the duty of care.

6. Commercial Implications: Competitive Advantage and Risk Management

Companies that comply with the standard gain a stronger position in international markets and present a more reliable profile to investors and financial institutions. This facilitates access to finance and strengthens commercial relationships.

Conversely, companies that fail to present carbon data in accordance with standards may face risks such as trade restrictions, increased costs, and loss of market access.

In this respect, the TS EN ISO 14064-1 standard stands out not only as a compliance tool but also as a strategic instrument that provides competitive advantage.

7. Evaluation from the Perspective of Law Firms

Carbon management and related obligations are creating a new area of specialization in legal practice. In this context, law firms play an important role in areas such as the legal review of carbon reports, the integration of ESG obligations into contracts, and the management of compliance processes.

The field of carbon and ESG has become a multidimensional advisory area requiring the collaboration of technical and legal disciplines.

8. Conclusion

The TS EN ISO 14064-1:2019 standard has evolved beyond being merely a technical reporting process and has become a fundamental framework directly affecting companies’ legal compliance, commercial sustainability, and corporate governance structures.

In light of increasing international regulations and market expectations, managing carbon data in a standardized, transparent, and verifiable manner is of critical importance for minimizing legal risks and maintaining competitiveness.

In this context, compliance with the TS EN ISO 14064-1 standard is not merely a choice but a strategic necessity for companies to operate effectively and sustainably in the global economy.

Accordingly, we are of the view that properly structuring carbon footprint calculation and carbon reporting processes has become critical for companies to operate sustainably and competitively both in Türkiye and in international markets.