On paper, the CSRD reform looked settled. Companies had mapped their reporting calendars, assigned sustainability teams, and begun gap analyses. Then the European Commission introduced the Omnibus package and the Stop-the-Clock mechanism – reshuffling deadlines, narrowing scope, and leaving compliance officers across Poland asking the same question: what do we actually need to do now?

The Omnibus proposal and the accompanying Stop-the-Clock directive would delay CSRD obligations for wave-two and wave-three companies by two years, reducing the number of in-scope entities across the EU by an estimated 80 percent. For Polish companies, the practical effect is a revised reporting calendar: large public-interest entities already reporting under the National Court Register (KRS) disclosure regime remain in wave one, while most remaining large companies and listed SMEs gain until financial year 2027 at the earliest. The Polish Financial Supervision Authority (KNF) and the Financial Reporting Standards Committee continue to monitor transposition, meaning domestic rules may tighten independently of the EU timeline.

This guide walks through the key changes step by step: what the Omnibus and Stop-the-Clock actually say, who remains in scope in Poland, how the revised timeline affects your planning, and what mistakes to avoid. Three business scenarios – a manufacturing group, an IT services firm, and a foreign investor – illustrate the practical stakes.

What did the Omnibus package and Stop-the-Clock actually change?

The Omnibus package is a set of legislative proposals tabled by the European Commission in early 2025. Its central aim is to reduce the administrative burden of sustainability reporting. Stop-the-Clock is the fast-track directive within that package. It pauses the application of CSRD obligations for wave-two and wave-three companies while the broader Omnibus amendments are negotiated. The two-year delay is not automatic – it requires formal adoption of the directive into Polish law, which must occur within the transposition window.

Three changes are most significant for Polish entities. First, the scope threshold rises sharply. Under the revised proposal, only companies with more than 1,000 employees would remain subject to mandatory CSRD reporting in the medium term. Second, the European Sustainability Reporting Standards (ESRS) would be simplified, with many disclosure points becoming voluntary rather than mandatory. Third, the value-chain information requests that large companies could direct at smaller suppliers would be capped, protecting Polish SMEs from indirect compliance pressure. Each of these shifts has a direct cost implication: compliance budgets calibrated to the original CSRD timetable may now be over-engineered.

What has not changed is the obligation for wave-one entities. Companies already reporting under the Corporate Sustainability Reporting Directive for financial year 2024 – primarily large public-interest entities with more than 500 employees – continue on the existing schedule. The Polish Ministry of Finance has not signalled any domestic extension for this group. Businesses that fall into this category cannot treat the Omnibus debate as a reason to pause.

  • Wave-one entities (500+ employees, public-interest): no change, FY 2024 reports due in 2025
  • Wave-two large companies: proposed delay to FY 2027 under Stop-the-Clock
  • Wave-three listed SMEs: proposed delay to FY 2028 under Stop-the-Clock
  • Non-EU parent companies with Polish subsidiaries: third-country rules under review

Which Polish companies remain in scope after the proposed changes?

Scope under the revised Omnibus proposal turns on three cumulative criteria: more than 1,000 employees on a consolidated basis, net turnover above EUR 50 million, and total assets above EUR 25 million. A company must exceed all three thresholds to fall within the mandatory reporting regime. For Poland, this narrows the in-scope universe substantially – the original CSRD would have captured roughly 3,500 Polish entities; the revised threshold is expected to reduce that figure to under 700.

Foreign investors operating through Polish subsidiaries face a specific question. A German manufacturing group with a Polish subsidiary employing 800 people locally may fall outside the Polish threshold individually, but the parent's CSRD obligations will cascade down through group-level reporting. We secured a reversal of an over-broad ESG data request for a manufacturing client in the Mazowieckie region (autumn 2025), where the subsidiary had been treating parent-level CSRD obligations as its own standalone duty – a costly misreading. The distinction between group-level and entity-level scope is one of the most common sources of compliance error in Poland right now.

Listed SMEs registered on the Warsaw Stock Exchange (Giełda Papierów Wartościowych, GPW) occupy a separate category. They were originally scheduled for wave three, with reporting obligations from FY 2026. Under Stop-the-Clock, that shifts to FY 2028 at the earliest. GPW-listed companies should nonetheless continue preparatory work: auditors and institutional investors are already requesting ESG data voluntarily, and the two-year window will pass quickly if internal data systems are not in place. For more on building those systems, see our step-by-step breakdown at ESRS implementation steps for Polish reporting entities.

How does the revised timeline affect your compliance planning?

The Stop-the-Clock delay does not eliminate the obligation – it defers it. Companies that use the two-year window to disengage entirely risk arriving at FY 2027 with no data infrastructure, no internal governance framework, and no auditor relationship for sustainability assurance. The cost of a rushed build in 2027 will exceed the cost of a phased build starting now. A reasonable planning horizon for wave-two companies is 18 months of active preparation before the first reporting year.

Three scenarios illustrate the planning calculus. A Polish manufacturing group with 1,200 employees and EUR 80 million in turnover falls squarely within the revised scope. It should complete a materiality assessment by Q3 2026, implement data collection for the ESRS climate and social disclosures by Q1 2027, and engage an assurance provider by mid-2027. An IT services firm with 950 employees sits just below the 1,000-employee threshold. It should monitor headcount growth and keep a light-touch ESG baseline ready to activate if it crosses the threshold before FY 2027. A foreign investor entering Poland through an acquisition should assess whether the target's employee count, combined with group-level headcount, triggers consolidated reporting obligations immediately – not after integration.

Our team obtained early-stage compliance clearance for a technology investor's Polish subsidiary in Lower Silesia (spring 2026), where the acquisition target's 600-person workforce, when consolidated with the parent group, pushed total headcount above 1,000 within the first reporting year. The lesson: due diligence for M&A transactions in Poland now requires an ESG scope analysis as a standard line item. For foreign investment screening more broadly, see our note on foreign investment screening in Poland – UOKiK powers.

What are the most common compliance mistakes under the new framework?

The first mistake is treating Stop-the-Clock as a full stop. The directive delays mandatory reporting; it does not suspend voluntary disclosure, contractual ESG obligations to lenders or investors, or sector-specific requirements under Polish financial regulation. Companies with sustainability-linked loan covenants face a contractual reporting duty regardless of the statutory timeline. Missing a covenant reporting date carries immediate financial consequences – margin ratchets, technical defaults, and in some cases acceleration of the facility within 30 days.

The second mistake is ignoring the value-chain effect. Even if your company falls outside the revised CSRD scope, a large customer or parent that remains in scope will need your ESG data to complete its own report. Refusing or failing to provide that data does not remove your exposure – it shifts it from regulatory to commercial. Losing a key supply contract because you cannot provide a basic carbon footprint figure is a real and recurring outcome. AML and whistleblower compliance obligations, which sit alongside ESG reporting in many companies' governance frameworks, add a further layer: failures in one area tend to surface weaknesses in others during audits. For a parallel compliance structure example, see our analysis of compliance programme design for Cyprus subsidiaries in Poland.

The third mistake is underestimating assurance costs. The revised ESRS would require limited assurance from an accredited auditor. In Poland, the pool of auditors with sustainability assurance accreditation is still small. Waiting until 2027 to engage an assurance provider means competing for scarce capacity at premium rates. Companies that engage early – even for pre-assurance readiness reviews – secure better pricing and identify data gaps with enough time to fix them.

  • Confirm whether your company is in wave one, two, or three under the revised thresholds
  • Review loan covenants and investor agreements for standalone ESG reporting obligations
  • Map value-chain data requests from customers and parent entities
  • Begin a materiality assessment even if full reporting is deferred
  • Identify and engage an assurance provider at least 12 months before the reporting deadline

Specific situations require tailored analysis. If your company's headcount is near the 1,000-employee threshold, a single significant hire or acquisition can shift your obligations within a financial year. The irreversible consequence of misclassifying your scope is a first-year report produced under time pressure, with data gaps that an auditor will flag – and that regulators will notice. Personal liability for board members under Polish corporate legislation arises where disclosure failures are attributable to governance decisions, not just operational oversight.

For a tailored strategy on CSRD scope analysis and readiness planning, reach out to info@kordeckipartners.com.

Frequently asked questions

Q: Does Stop-the-Clock mean Polish companies can stop all CSRD preparation work?

A: No. Stop-the-Clock delays the statutory reporting obligation for wave-two and wave-three companies, but it does not affect contractual ESG commitments to banks or investors, voluntary disclosures, or the data collection work needed to meet the eventual deadline. Companies that pause entirely will face a compressed and more expensive build in 2027. A minimum baseline – materiality assessment and data gap analysis – should continue regardless of the statutory timeline.

Q: How long does a CSRD readiness project typically take and what does it cost?

A: A full readiness project for a mid-sized Polish company – covering materiality assessment, ESRS gap analysis, internal data system design, and assurance preparation – typically runs 12 to 18 months. Legal and advisory costs vary widely, but companies should budget for both internal resource allocation and external advisory fees. Engaging earlier, before the 2027 deadline pressure builds, generally reduces total cost by 20 to 30 percent compared with a rushed timeline.

Q: Is it a common misconception that only listed companies need to report under CSRD?

A: Yes, and it is one of the most persistent errors. CSRD applies to large companies meeting the employee and financial thresholds, whether listed or not. Many privately held Polish companies with significant turnover or workforce size fall within scope. The listing requirement applies only to the SME category, where listed SMEs on regulated markets face a separate – and now deferred – reporting obligation. Unlisted large companies should assess their own position independently of GPW listing status.

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 readiness, and sustainability reporting 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.