A mid-sized Polish manufacturing company – supplying automotive components from its plant in the Silesia region – faced its first Corporate Sustainability Reporting Directive (CSRD) reporting cycle in early 2026. Management had heard the term "double materiality" but had no structured process in place. The gap between regulatory expectation and internal readiness was significant.

CSRD double materiality assessment requires companies to evaluate both how sustainability matters affect their financial performance (financial materiality) and how their operations affect people and the environment (impact materiality). Under Polish law, the obligation flows from the transposition of the EU CSRD framework into the Accounting Act (ustawa o rachunkowości). Companies in scope for the first reporting wave must complete this assessment before finalising their sustainability statement – a step that cannot be skipped without risking a materially incomplete report.

This case study traces the full arc of one such assessment: the client's starting position, the legal and methodological strategy we applied, the process we ran, and the transferable lessons for other Polish entities facing the same obligation in 2026 and beyond.

What was the client's starting position?

The client was a limited liability company (spółka z ograniczoną odpowiedzialnością, sp. z o.o.) with approximately 600 employees and consolidated revenue crossing the CSRD threshold. It was subject to oversight by the Polish Financial Supervision Authority (KNF) on certain financial instruments and was registered in the National Court Register (KRS). No sustainability reporting infrastructure existed. The company had a basic code of conduct but no formal ESG reporting, no whistleblower compliance channel meeting the requirements of the Whistleblower Protection Act, and no AML risk mapping linked to sustainability topics.

Three structural gaps emerged immediately. First, the company had never mapped its value chain – a prerequisite for identifying impacts beyond the factory gate. Second, internal stakeholders disagreed on which topics were "material." Third, management assumed that double materiality was a single spreadsheet exercise. It is not. It is a governed, documented process with audit-trail requirements under the European Sustainability Reporting Standards (ESRS).

The financial exposure was real. Incomplete or methodologically deficient sustainability statements expose Polish entities to regulatory scrutiny from the Financial Reporting Council and, from 2026, to statutory audit requirements covering sustainability data. Missing the assessment entirely forfeits the company's ability to demonstrate ESRS compliance – a gap that cannot be remedied retroactively once the reporting period closes.

What strategy and process did we apply?

We structured the engagement in three phases, each with a defined output and a maximum timeline of 10 weeks. Phase one covered scoping and stakeholder mapping. Phase two covered the materiality workshops and scoring. Phase three produced the documented assessment matrix and legal sign-off memo.

In phase one, we identified the client's value chain – upstream suppliers of steel and polymer inputs, downstream Tier 1 automotive assemblers – and mapped 14 potential sustainability topics across environmental, social, and governance dimensions. We used ESRS topical standards as the reference list, not an internal guess. This took three weeks. We also reviewed the company's existing compliance programme design, identifying gaps against the requirements described in our guide on compliance programme design for Luxembourg subsidiaries in Poland.

Phase two ran four structured workshops. Each workshop addressed one ESRS cluster: environment (E1–E5), social – own workforce (S1), social – value chain workers (S2), and governance (G1). Participants included the CFO, head of operations, HR director, and an external supplier representative. We scored each topic on two axes: magnitude of impact and financial significance. Topics scoring above the agreed threshold on either axis were designated material. We secured a final list of seven material topics within six weeks of starting – a timeline that satisfied the client's statutory audit preparation window.

We also flagged that the client's logistics contracts contained sustainability clauses that created potential liability exposure. That analysis drew on the framework discussed in our article on warehouse and logistics contracts under Polish law.

Our team completed the full double materiality assessment and documentation package for this Silesia-based manufacturing client within the agreed 10-week window (winter 2026). The output included a board-approved materiality matrix, a stakeholder engagement log, and a legal memo confirming ESRS procedural compliance.

What are the transferable lessons for Polish companies?

The most common mistake Polish companies make is treating double materiality as a data-collection task rather than a governance process. ESRS requires documented evidence of how the assessment was conducted, who was consulted, and how scores were assigned. A spreadsheet without minutes, sign-offs, and a stakeholder log will not survive audit scrutiny.

Four lessons from this engagement apply broadly:

  • Start with ESRS topical standards, not internal assumptions – they define the universe of topics you must consider.
  • Involve value chain actors early – their input affects impact materiality scores and must be documented.
  • Align the assessment timeline with your statutory audit preparation – auditors will request the materiality matrix as a primary input.
  • Treat whistleblower compliance and AML risk mapping as ESG reporting inputs, not separate workstreams.

A second practical lesson concerns Czech and other Central European subsidiaries operating in Poland. The governance expectations under CSRD are consistent across EU member states, but local transposition details vary. Our parallel work on compliance programme design for Czech Republic subsidiaries in Poland illustrates how group-level materiality assessments must account for local regulatory overlays – including Polish-specific whistleblower protection obligations that came into force in September 2024.

For a Małopolska-based IT services company we advised, the same three-phase methodology produced a materiality matrix in eight weeks – two weeks faster than the manufacturing client – because the value chain was shorter and stakeholder mapping was simpler (spring 2026). The core process was identical. The lesson: methodology scales across sectors.

Companies that complete a well-documented double materiality assessment gain a durable advantage. The matrix drives disclosure decisions for multiple reporting periods. It also signals to investors, lenders, and procurement teams that sustainability data is reliable – an increasingly material factor in financing terms and supply-chain qualification.

Your company's specific situation requires the same structured approach. Attempting the assessment without a governed process risks producing a document that fails audit review – an outcome that cannot be corrected after the reporting period closes.

If your company is preparing its first CSRD sustainability statement and needs a documented double materiality assessment – including stakeholder engagement, ESRS scoring, and legal sign-off – contact info@kordeckipartners.com.

Frequently asked questions

Q: How long does a double materiality assessment typically take for a Polish company?

A: For a mid-sized company with a defined value chain, the process takes between 8 and 12 weeks when run with structured workshops and clear stakeholder access. Compressed timelines are possible but require dedicated internal resources. Starting at least three months before the reporting period end date is advisable to leave time for board approval and audit preparation.

Q: Is it a common misconception that double materiality only applies to large listed companies?

A: Yes. While the first reporting wave covers large public-interest entities, the obligation extends to large non-listed companies meeting two of three thresholds – over 250 employees, EUR 25 million balance sheet, or EUR 50 million net turnover – from financial year 2025. Many Polish sp. z o.o. entities fall within scope and are not yet aware of the obligation.

Q: What does a double materiality assessment cost?

A: Cost depends on value chain complexity and the number of ESRS topics requiring detailed analysis. For a mid-sized manufacturing company, external legal and advisory fees for a full assessment – including documentation and legal sign-off – typically range from PLN 30,000 to PLN 80,000. Engaging early reduces cost; remediation after a deficient first attempt is consistently more expensive.

KORDECKI & Partners is a law firm based in Warsaw and Krakow, advising business clients across 30 jurisdictions. Our team combines expertise in Polish and international law with a practical approach to ESG compliance, CSRD reporting, and sustainability governance. We work with Polish entrepreneurs, foreign investors, and in-house legal teams. To discuss your situation, contact info@kordeckipartners.com.

Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. KORDECKI & Partners assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@kordeckipartners.com.