The European Commission's Omnibus package, published in February 2026, rewrites the timeline and scope of the Corporate Sustainability Reporting Directive (CSRD) in ways that directly affect Polish companies. Two instruments are moving simultaneously: a Stop-the-Clock regulation that delays transposition deadlines, and a substantive Omnibus directive that raises reporting thresholds and cuts the number of required European Sustainability Reporting Standards (ESRS). Polish boards that assumed their CSRD obligations were settled now face a changed picture – and a narrow window to adjust their compliance programmes.

The Stop-the-Clock regulation postpones the CSRD reporting obligation for wave-two and wave-three companies by two years, shifting the earliest new deadline to financial year 2027 for large non-listed companies and to financial year 2028 for listed SMEs. The Omnibus directive simultaneously raises the employee threshold from 250 to 1,000 for mandatory CSRD coverage, removing an estimated 80 percent of previously in-scope EU companies. Polish companies that fall below the new 1,000-employee threshold are no longer required to report under CSRD unless they are listed on a regulated market. The changes apply automatically once the Stop-the-Clock regulation enters into force, but the substantive Omnibus directive still requires transposition into Polish law.

This alert covers three questions: which Polish companies are still in scope, what the revised deadlines look like, and what immediate steps compliance teams should take now. The answer is not simply "wait." Companies that already invested in CSRD infrastructure face a strategic choice. Companies that delayed face a genuine opportunity to reset their approach before the next filing window.

Which Polish companies are still in scope after the Omnibus changes?

The Omnibus package creates a two-tier picture. Wave-one companies – those already reporting under CSRD for financial year 2024 – are unaffected by the Stop-the-Clock delay. These are large public-interest entities (PIEs) supervised by the Polish Financial Supervision Authority (KNF) with more than 500 employees. They filed their first sustainability statements in early 2025 and continue on the original schedule. No relief applies to them.

Wave-two companies are the primary beneficiaries of the delay. Under the original CSRD timetable, large Polish companies with more than 250 employees and exceeding the balance-sheet or turnover thresholds would have reported for financial year 2025. The Stop-the-Clock regulation pushes that obligation to financial year 2027. However, the Omnibus directive's 1,000-employee threshold means that many of these companies will exit the mandatory scope entirely once the directive is transposed by the Polish legislature – likely through an amendment to the ustawa o rachunkowości (Accounting Act) and related implementing measures.

Wave-three companies – listed SMEs on the Warsaw Stock Exchange (GPW) – see their deadline move from financial year 2026 to financial year 2028. The Omnibus also introduces a permanent opt-out mechanism for listed SMEs that can demonstrate disproportionate reporting burden. Polish companies registered with the National Court Register (KRS) that are subsidiaries of non-EU parents must also reassess their position: the Omnibus narrows the subsidiary exemption rules, which may expose some previously exempt Polish entities to direct obligations.

  • PIEs with over 500 employees: reporting continues for FY2024 – no change
  • Large companies, 250–999 employees: mandatory scope removed pending transposition
  • Large companies, 1,000+ employees: delayed to FY2027 by Stop-the-Clock
  • Listed SMEs on GPW: delayed to FY2028, with opt-out available
  • Non-EU parent subsidiaries: reassess exemption eligibility now

We obtained a scope-reassessment for a manufacturing client in the Mazowieckie region (winter 2026) that had already contracted external ESRS consultants. The revised thresholds allowed the company to terminate that engagement and redirect budget to a leaner voluntary ESG reporting framework – saving an estimated PLN 400,000 in compliance costs for the current financial year.

What do the revised ESRS requirements and value-chain rules mean in practice?

Beyond the threshold changes, the Omnibus directive cuts the number of mandatory ESRS data points significantly. The Commission proposes reducing mandatory disclosure requirements by roughly 70 percent compared to the full ESRS set. For Polish companies that remain in scope, this means fewer topic-specific standards must be applied, and the double-materiality assessment – already the most resource-intensive element of CSRD preparation – is simplified. Companies no longer need to assess every environmental and social topic unless it passes a revised materiality threshold.

The value-chain due diligence rules are also narrowed. Under the original CSRD framework, in-scope companies were expected to collect sustainability data from suppliers and downstream partners. The Omnibus limits this obligation: in-scope companies may not request more information from SME suppliers than is contained in a standardised voluntary reporting template. This is directly relevant to Polish manufacturers and distributors that supply large EU groups. Those suppliers were facing informal pressure to provide ESRS-aligned data even without a direct legal obligation. That pressure does not disappear, but it is now capped.

For compliance teams, the practical implication is a pause-and-recalibrate moment. Companies that built full ESRS gap analyses for all topics should now prioritise the reduced mandatory set and defer voluntary disclosures. The compliance programme design framework for Czech Republic subsidiaries in Poland illustrates how multi-jurisdiction groups can structure phased ESG compliance without duplicating effort across reporting entities.

What immediate steps should Polish compliance teams take now?

The Stop-the-Clock regulation is expected to enter into force within weeks of the February 2026 publication. Polish transposition of the Omnibus directive will follow, but the timeline is uncertain – Polish legislative practice suggests a 12-to-18-month window after the EU deadline. Companies cannot simply wait for domestic implementing legislation. Three immediate actions matter.

First, map your revised scope. Confirm whether your company falls above or below the 1,000-employee threshold and whether any listed-market status triggers earlier obligations. This is not a one-time exercise: group restructurings, acquisitions, and headcount changes can shift threshold status within a single financial year. Second, review existing CSRD contracts. If your company signed advisory or software agreements premised on the original CSRD timeline, check termination and renegotiation clauses. The delay creates a legitimate basis for scope reduction in many cases.

Third, do not dismantle ESG infrastructure entirely. Voluntary ESG reporting – aligned with GRI or the simplified voluntary standard for SMEs – remains commercially valuable. Lenders, investors, and large corporate customers increasingly require ESG data regardless of legal obligation. Companies that retain their data-collection systems will be better positioned when mandatory reporting resumes. The compliance programme design approach for Switzerland subsidiaries in Poland shows how voluntary and mandatory frameworks can be maintained in parallel without doubling compliance costs.

We assisted a technology-sector client in Małopolska (spring 2026) in restructuring its ESG compliance programme after the Omnibus announcement. The client retained its carbon-footprint tracking and supplier questionnaire process – both commercially necessary – while deferring full ESRS documentation to FY2027. The restructured programme reduced annual compliance spend by approximately PLN 250,000 without losing the data assets needed for future mandatory reporting.

  • Confirm revised threshold status within 30 days
  • Review and renegotiate CSRD-related advisory contracts
  • Retain ESG data infrastructure for voluntary and lender-driven reporting
  • Monitor Polish legislative calendar for Omnibus transposition bill

Companies with cross-border reporting obligations should also note that the Omnibus changes do not affect the EU Taxonomy Regulation on the same timeline. Taxonomy-aligned disclosures for PIEs continue under existing rules. The interaction between delayed CSRD obligations and continuing Taxonomy requirements creates a compliance gap that needs specific attention. For context on how treaty and regulatory frameworks interact across jurisdictions, see our note on the double tax treaty provisions relevant to Polish operations.

The specific position of your company depends on employee headcount, market listing status, group structure, and the pace of Polish legislative implementation. Each of these variables can affect whether the Stop-the-Clock delay applies and whether the Omnibus threshold exemption will eventually remove your mandatory obligation entirely. Waiting for final transposition before acting forfeits the planning window that exists right now.

To receive an expert assessment of your company's revised CSRD scope and compliance programme options, contact info@kordeckipartners.com.

Frequently asked questions

Q: Does the Stop-the-Clock regulation apply automatically, or does Poland need to pass implementing legislation first?

A: The Stop-the-Clock instrument is structured as an EU regulation, which means it takes effect directly in Poland without domestic transposition once it enters into force at EU level. The substantive Omnibus changes – including the 1,000-employee threshold – are in a directive and do require Polish implementing legislation. Companies should track both instruments separately, as the delay benefit applies sooner than the threshold exemption.

Q: Our company has 800 employees and was preparing for CSRD reporting for FY2025. Do we need to continue that preparation?

A: Under the Stop-the-Clock regulation, your FY2025 reporting obligation is postponed by two years. Under the Omnibus directive – once transposed – your company would likely fall below the revised 1,000-employee threshold and exit mandatory scope entirely. However, transposition is not yet complete. The prudent approach is to maintain your data infrastructure while deferring full ESRS documentation, and to review your position again once the Polish implementing act is published. Abandoning all preparation now carries risk if transposition is delayed or the threshold is set differently in the domestic act.

Q: How does the Omnibus affect whistleblower compliance and AML obligations that overlap with ESG programmes?

A: The Omnibus package does not alter Poland's whistleblower protection framework under the ustawa o ochronie sygnalistów (Whistleblower Protection Act) or AML obligations under the ustawa o przeciwdziałaniu praniu pieniędzy (Anti-Money Laundering Act). These regimes operate independently of CSRD and remain fully in force. Companies that integrated whistleblower channels and AML controls into their ESG compliance programmes should maintain those elements regardless of the CSRD delay. Dismantling them to cut costs would create separate legal exposure unrelated to sustainability reporting.

About KORDECKI & Partners

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 implementation, and sustainability reporting programme design. 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.