01What this tool is, and what it is not
The COP31 Alignment Radar is a free self-assessment tool that makes a company's readiness for Türkiye and EU climate regulation visible, based on the company's own declarations. Its purpose is to bring obligations run separately by different authorities into a single decision table and to make it concrete where to start.
The difficulty companies face with climate regulation is often not a lack of information but fragmentation: the emissions permit sits with one authority, the sustainability report with another, and the carbon border adjustment with the EU buyer. This tool shows on one screen where the same company stands across these separate timelines.
The tool does not produce
- A legal opinion or legal advice
- A declaration of conformity, a compliance certificate or any other certification
- An independent audit or assurance report
- Any document that can be used in official submissions
Outputs are intended for internal planning and prioritisation. Final scope determination and the interpretation of obligations remain the responsibility of the company's own legal counsel, financial adviser or authorised auditor.
The tool runs in your browser. It requires no installation, no membership and no account.
02Scoping rules
The short company profile questions in the tool's first step produce a scope label for each module. All the rules that set this label are explained below. There is no closed algorithm and no undisclosed scoring.
| Module | Labelling rule | Basis |
|---|---|---|
| TR ETS | Scope signal: Legal headquarters in Türkiye; activity in one of the pilot-period sectors (power generation, cement, iron and steel, aluminium, fertiliser) and a Category B facility (above 50,000 and up to 500,000 tonnes CO2e) or a Category C facility (above 500,000 tonnes CO2e). Verify: The sector or the emissions category is not known. Monitor: Category A facilities and Annex 1 activities outside the pilot period (these are out of scope during the pilot period; the first application period begins in 2028), and companies legally headquartered outside Türkiye. | Türkiye Emissions Trading System Regulation (27 August 2026) and Carbon Market Board decision KPK/2026/1 (3 September 2026) |
| TSRS | Scope signal: Banks regulated and supervised by the BRSA (BDDK), with no threshold applied; or Türkiye-based companies included in list (II) that exceed at least two of the three criteria — total assets of TRY 1 billion, annual net sales of TRY 2 billion and an average of 500 employees — in two consecutive reporting periods. Verify: Only one criterion is exceeded, a criterion is not known, you are not sure about the two-period condition, or at least two criteria are exceeded but you are not sure whether you are included in list (II). Monitor: The criteria are not exceeded, you are not included in list (II), or your legal headquarters are outside Türkiye. | KGK Board Decision on threshold values of 16 January 2026 (accounting periods beginning on or after 1 January 2025) |
| CBAM | Scope signal: You export CBAM-covered goods to the EU (iron and steel, aluminium, cement, fertilisers, electricity, hydrogen) and the annual cumulative net mass is 50 tonnes or more; or you export hydrogen or electricity (the 50-tonne exemption does not apply to these two goods). Verify: You are not sure about your export status or the mass of your shipments. Monitor: You do not export CBAM goods to the EU, or your annual shipments are below 50 tonnes. | Regulation (EU) 2023/956, as amended by Regulation (EU) 2025/2083, and its Annex I product list |
| CSRD | Verify: You are established in the EU and have an average of 1,000 or more employees; or you have a large EU-based parent company or a high-turnover EU subsidiary or branch. Because the tool does not ask about the turnover threshold, this module never produces a scope signal; it always asks for verification. Monitor: Your EU connection is small in scale, or you have none. | CSRD scope as narrowed by Omnibus I — Directive (EU) 2026/470 |
| Voluntary | This module is never shown as a legal obligation; its label is always Monitor. If you did not answer "No" to the voluntary visibility question, or if your customers request sustainability data, the module enters the overall score with the lowest weighting factor (see Scoring formula). | GRI, CDP, SBTi and ISSB baseline disclosures |
What the scope labels mean
- SCOPE SIGNAL
- The profile you declared appears to meet the scope criteria the tool checks for this regime. This is not a scope determination; it is a signal that the regime deserves a closer look.
- VERIFY
- Your answers are incomplete, include "not sure", or meet only some of the criteria. Your scope status should be confirmed with your own legal and financial advisers. Modules with this label are included in the overall score.
- MONITOR
- Based on your answers, the regime does not currently point directly at you; this can change as thresholds, sector lists and timelines change. Under CBAM, the legal obligation sits with the importer in the EU; even so, supplying embedded-emissions data accurately and on time is in practice a precondition of the buyer relationship for a Turkish exporter. Modules labelled Monitor can still be opened and completed voluntarily; for many companies, this is how to prepare before crossing the thresholds.
Threshold values and sector lists are updated as the regulations change. A "not sure" answer in the profile questions does not take the relevant module out of scope; it shows the module as requiring verification. Missing information does not mean there is no obligation.
Regulations still in the legislative process (for example, the extension of CBAM to downstream products) are not shown as current obligations; they appear only on the watchlist.
03Sources
The checklist items are derived from the primary sources below. Most items correspond to an action the regulation directly requires; points that involve interpretation are flagged separately in the description of the item concerned.
Türkiye Climate Law and Emissions Trading System — 17 items
- Climate Law No. 7552 (9 July 2025)
- Türkiye Emissions Trading System Regulation (27 August 2026) — Annex 1 activity list, emissions permit document set, monitoring plan principles and annual reporting format
- Carbon Market Board decision KPK/2026/1 (3 September 2026) — pilot-period scope and free allocation
- Implementation announcements of the Presidency of Climate Change and the list of accredited verification bodies published through MEDAS
Timeline: the Regulation entered into force on 27 August 2026. The pilot period covers the 2026 and 2027 system years; in 2026, businesses in scope are subject to reporting obligations only, and the price mechanism begins in the 2027 system year. Free allocation is set at 100% throughout the pilot period, using the benchmark method. The first Monitoring Methodology Plan is due on 27 October 2026. The first application period covers 2028–2035. Sources: Official Gazette (Resmî Gazete), Presidency of Climate Change.
TSRS and sustainability assurance — 15 items
- TSRS 1 and TSRS 2 — Public Oversight, Accounting and Auditing Standards Authority (KGK)
- ISSB IFRS S1 and S2 — the international standards with which TSRS is aligned
- KGK Board Decision on threshold values of 16 January 2026 — accounting periods beginning on or after 1 January 2025
- Amendments to TSRS 2 on the disclosure of greenhouse gas emissions (31 July 2026)
Mandatory reporting has applied to entities in scope for accounting periods beginning on or after 1 January 2024. The numerical thresholds may be reset periodically; the tool is checked against the KGK's current Board decision before every release. Source: KGK.
EU Carbon Border Adjustment Mechanism — 11 items
- Regulation (EU) 2023/956, the amendments made by Regulation (EU) 2025/2083, and the Annex I product list
- Methods for calculating embedded emissions — the EU method, equivalent methods and the rules on default values
- The annual 50-tonne de minimis threshold (excluding hydrogen and electricity) and the rules on authorised declarant status
The definitive period began on 1 January 2026. Certificates corresponding to 2026 imports go on sale on 1 February 2027; the first annual declaration and certificate surrender is due on 30 September 2027. The mark-up applied to default values is 10% for 2026, 20% for 2027 and 30% for 2028 onwards. The extension of CBAM to downstream products containing steel and aluminium is still in the legislative process; the tool lists it on the watchlist only. Sources: EUR-Lex, European Commission, Taxation and Customs Union.
EU CSRD scope test — 6 items
- Corporate Sustainability Reporting Directive
- Omnibus I — Directive (EU) 2026/470: Official Journal of the EU on 26 February 2026, in force on 18 March 2026. According to the Commission's estimate, the number of companies in scope falls by around 80%.
- Simplified ESRS
Under the new scope, mandatory reporting covers companies with more than 1,000 employees and net turnover above €450 million; both criteria must be exceeded together. For parent companies outside the EU, the test is net turnover above €450 million within the EU together with an EU subsidiary or an EU branch with net turnover above €200 million. The new scope applies from financial year 2027.
For most Türkiye-based companies this module is out of direct scope; it offers a scope test for groups with an EU subsidiary, branch or large parent company. Companies outside direct scope may still receive value-chain information requests through an EU parent or corporate customer; Omnibus I has limited these requests but has not removed them altogether.
Voluntary frameworks — 6 items
- GRI Standards
- CDP climate questionnaire
- SBTi science-based target-setting process
- ISSB baseline disclosures
Regulatory texts can change. For critical decisions, confirm the current version of the underlying regulation from the official sources above. The summaries on this page do not replace the regulatory text.
04Weighting
Each item in the checklist carries a weight from 1 to 3. The weight reflects how serious the consequence of leaving the item incomplete would be, and how much time pressure it is under. Each item's weight is shown next to the item in the tool's checklist.
| Weight | What it means | Example |
|---|---|---|
| 3 | An item with a direct legal consequence, where a gap could lead to administrative sanctions or a commercial disruption | The annual emissions report being ready on time; an accredited verification body having been selected; the audit evidence pack being kept systematically |
| 2 | An intermediate step needed to meet the obligation | Assigning staff responsible for monitoring; the reporting template matching the required format; setting up a data-sharing process with the buyer |
| 1 | Good practice — strengthens readiness but is not mandatory on its own | Holding a preliminary discussion with a verification body; setting up a certificate-price tracking mechanism |
Modules also carry a priority factor: 3 for TR ETS, TSRS and CBAM, 2 for CSRD and 1 for voluntary frameworks. This factor is used to calculate the overall score and the priority action list.
The weights are not defined in regulation
No regulator has assigned such a priority order to the checklist items or the modules. The item weights and module factors were set by Omnius Creative, taking into account the legal consequence of each obligation and the pressure of its timeline.
This is the most debatable part of the tool, and it is deliberately kept visible. If you think an item's weight is wrong, you can treat that item as a higher priority for your own organisation and let us know.
05Scoring formula
Each checklist item is marked on a four-level status scale. The module score is the weighted points achieved as a share of the maximum weighted points available.
Overall score = Σ(module score × module factor) ÷ Σ(module factor)
status values — Not started: 0 · In progress: 1 · Ready: 2 · Verified: 3
module factors — TR ETS: 3 · TSRS: 3 · CBAM: 3 · CSRD: 2 · Voluntary: 1
Example: if every item in a module is marked "Ready" (2), the module score is 2 ÷ 3 = 67%. The maximum score is reached only when items move to "Verified".
This is a deliberate design choice. Having finished the work by your own account is not the same as having independent confirmation, and the tool does not give the two the same score.
Only modules labelled Scope signal or Verify enter the overall score. The voluntary frameworks module is included with the lowest factor if you did not answer "No" to the voluntary visibility question or if your customers request sustainability data. Other modules labelled Monitor do not affect the overall score; seeing 0% in such a module does not lower your overall result.
Priority action list
The dashboard shows an action list of up to 10 items. Only items not yet marked "Ready" or "Verified" in modules that count towards the overall score are included, ranked by item weight multiplied by module factor. As a result, the top of the list shows the highest-weighted open items in a regime that gives a scope signal or requires verification.
06Status definitions and self-declaration
The difference between the four status levels — especially between "Ready" and "Verified" — is critical for the tool to work meaningfully.
- Not started
- No work has yet been done on the item.
- In progress
- Work has started but is not complete; the output is not yet usable.
- Ready
- The action is complete and documented internally. There is a named owner, and the relevant record or document exists and can be found. It has not yet been confirmed by anyone outside the organisation.
- Verified
- Confirmed by an independent third party, an accredited verification body or a competent public authority, and the evidence of that confirmation is kept.
All markings are self-declared
The tool does not verify any evidence. No documents are uploaded, no systems are connected and no records are checked in the background. The person who marks an item "Verified" is the user, and the tool cannot confirm that the mark is true.
The outputs are therefore only as reliable as the knowledge and honesty of the person doing the marking. The tool's value lies not in verification but in showing which questions need to be asked.
In practice, the most useful approach is for the relevant departments to complete the list together rather than one person alone. When different departments mark the same item differently, that often reveals the responsibility gap itself.
07What a high score does not mean
The readiness score is not a compliance indicator. A high score does not mean:
- That you comply with the regulations
- That you will pass an audit, or that you face no risk of sanctions
- That your emissions have fallen or that your climate performance is good
- That the content of your reports is accurate or sufficient
The score shows only one thing: how much of the checklist you have completed, by your own account.
Readiness and performance are different things. A complete checklist can exist in a high-emitting company, while a low-emitting company may have gaps in its documentation. This tool measures the latter, not the former.
Use in corporate communication
This score is not designed to be used as corporate communication material. Presenting it as a mark of success in advertising, a sustainability report, a tender file or an investor presentation creates a greenwashing risk and goes against the purpose of the tool.
The tool is an internal working indicator designed to make gaps visible. The right way to use it is not to share the score, but to close the gaps the score points to.
08Data, privacy and updates
Where your data goes
All your answers are stored only in your own browser's local storage. No data is sent to Omnius Creative, to third parties or to any server. No sign-up, membership or email address is required. You can also use the tool offline.
If you clear your browser data or press the "Reset" button in the tool, your answers are deleted permanently. Use the PDF or CSV export to keep your work.
Transparency
The tool is offered free of charge under the CC BY-NC 4.0 licence. The scoping rules, checklist items and weights are openly visible on this page and in the tool's own interface; there is no hidden calculation layer. The tool's source code is published on GitHub.
The methodology was prepared by Omnius Creative and, in this version, has not been reviewed by an independent organisation. If such a review takes place, the reviewer and their organisation will be named in this section.
Update policy
The regulations covered are changing fast. Sources are reviewed every three months, and also whenever a significant regulatory change occurs. The "last regulatory check" date at the top of this page shows when this review was last carried out.
Check this date before using the tool. If it is more than a few months old, confirm the current state of the regulations from the primary source before making critical decisions.
Changelog
- Tool v0.2.3 — Fixed the TSRS scope label: when at least two criteria are exceeded in two consecutive periods and the list (II) question is answered "Not sure", the module now shows Verify instead of Monitor and counts towards the overall score. The previous version showed Monitor in this case, contrary to this page's rule that "not sure" answers do not take a module out of scope.
- Tool v0.2.2 · Methodology 2026.10 — This page was rewritten to match the tool's current rules: TR ETS pilot-period scope (KPK/2026/1), the TSRS threshold rule and the BRSA (BDDK) exception, the 50-tonne CBAM exemption, CSRD thresholds after Omnibus I, the "Scope signal / Verify / Monitor" labels and the overall score weighted by module factor. First publication of the English version.
- The tool was published on omniuscreative.com and the methodology page was first published in Turkish. 5 modules, 55 checklist items.
Future regulatory updates and item changes will be published in this list with their dates.
Feedback
Objections and corrections on the scoping rules, the weighting or the basis of any checklist item are welcome. Criticism of the methodology is the main way the tool improves. You can reach us through Omnius Creative.