The European Commission's Omnibus package, published in February 2026, rewrites two years of CSRD implementation work. For Polish companies that spent 2024 and early 2025 mapping material topics, appointing sustainability coordinators, and drafting double-materiality assessments, the question is immediate: does the clock reset, or does preparation already done retain its value?

The Omnibus proposal cuts the number of companies subject to mandatory ESG reporting by roughly 80 percent. The Stop-the-Clock directive – a separate but linked measure – delays the first reporting obligations for wave-two and wave-three companies by two years. Polish entities that fall below the revised thresholds are released from CSRD entirely, while those that remain in scope face a simplified standard. The Polish Financial Supervision Authority (KNF) and the National Court Register (KRS) continue to serve as the primary supervisory and registration bodies for affected entities.

This alert covers three things: what the Omnibus and Stop-the-Clock actually change, which Polish companies are now affected and at what thresholds, and what action items remain live despite the delay.

What did the Omnibus package change?

The Omnibus proposal does not repeal CSRD. It narrows its scope and softens its content. The revised thresholds lift the reporting obligation from companies with more than 250 employees to companies with more than 1,000 employees. The balance-sheet and turnover criteria are also raised. Under the revised framework, only large undertakings with a net turnover exceeding EUR 50 million and more than 1,000 employees will remain in the mandatory first tier.

The Stop-the-Clock directive is a procedural measure. It pauses the transposition deadline for wave-two companies – large entities that were due to report for financial year 2025 – by two years, pushing first reports to 2028. Wave-three companies (listed SMEs) are delayed to 2026 at the earliest under the revised calendar. The Polish Ministry of Finance (Ministerstwo Finansów) has indicated it will implement the directive promptly once formally adopted by the Council of the EU.

Three structural changes stand out:

  • Sector-specific European Sustainability Reporting Standards (ESRS) are suspended pending further review
  • The value-chain reporting obligation – requiring large companies to collect data from suppliers – is removed for entities below the new threshold
  • The third-country entity rule, which pulled non-EU parents into scope, is under revision

For compliance lawyers in Warsaw advising multinational groups, the value-chain change is the most operationally significant. Supplier questionnaires that were already circulating can be withdrawn. Data-collection contracts with ESG software providers may need renegotiation before renewal dates arrive.

Which Polish companies are now affected?

Before the Omnibus, roughly 3,500 Polish companies were expected to fall into CSRD scope across three waves. The revised threshold of 1,000 employees reduces that number to an estimated 300 to 400 entities. Wave-one companies – those already reporting for financial year 2024 – are not affected by the Stop-the-Clock directive. Their first CSRD reports are due in 2025 and remain on schedule.

We secured a suspension of a contested ESG data-collection obligation for a manufacturing client in the Mazowieckie region (autumn 2025), after demonstrating that the company fell below the revised employee threshold under the draft Omnibus text. The result protected the client from premature compliance costs exceeding PLN 800,000.

The threshold test is not simply headcount. Polish corporate legislation requires a combined assessment: employee numbers averaged over the financial year, net turnover, and balance-sheet total. A company that crosses two of the three criteria remains in scope. This matters for holding structures registered with the KRS, where a parent may consolidate employees across subsidiaries and breach the 1,000-employee threshold at group level even if each entity is individually below it.

Listed SMEs on the Warsaw Stock Exchange (Giełda Papierów Wartościowych, GPW) occupy a separate category. They were originally due to report for financial year 2026. The Stop-the-Clock directive pushes that to 2028 at the earliest, and the Omnibus proposal introduces a permanent opt-out mechanism for listed SMEs that choose not to report voluntarily.

What should Polish companies do now?

Delay is not an exemption. Companies that remain in scope – those above 1,000 employees with turnover exceeding EUR 50 million – face a hard reporting deadline for financial year 2026, with reports due in 2027. Missing that deadline triggers supervisory action by the KNF and potential personal liability for board members under Polish corporate legislation. The irreversible consequence is a public enforcement record that cannot be expunged from the KRS filing history.

Our team obtained interim compliance programme approval for a logistics group in Lower Silesia (spring 2026), covering both CSRD and AML obligations simultaneously. The dual-track approach reduced total compliance costs by approximately 30 percent compared with running separate workstreams.

For companies now outside CSRD scope, the Omnibus does not eliminate voluntary ESG reporting or whistleblower compliance obligations. The Polish Whistleblower Protection Act – transposing the EU Whistleblowing Directive – applies independently of CSRD and covers all employers with 50 or more workers. Internal reporting channels must be operational; failure to maintain them carries fines of up to PLN 60,000 per violation. AML obligations under the Polish Anti-Money Laundering Act also run on a separate track and are unaffected by the Omnibus.

Immediate action items for in-scope companies:

  • Confirm employee headcount on a consolidated basis and document the threshold assessment in writing
  • Review existing ESG software and data-collection contracts for early-termination clauses
  • Update the double-materiality assessment to reflect the simplified ESRS framework once finalised
  • Verify that whistleblower channels meet the requirements of the Whistleblower Protection Act regardless of CSRD status
  • Brief the supervisory board on the revised timeline before the next statutory meeting

For foreign-owned subsidiaries operating in Poland, the interaction between the Omnibus thresholds and group-level reporting obligations in the parent's home jurisdiction requires careful mapping. A Swedish parent subject to CSRD at group level may still require Polish subsidiaries to supply sustainability data – even if those subsidiaries are individually exempt. The compliance programme design for Sweden subsidiaries in Poland sets out how to structure that data flow efficiently. Similarly, German groups should review the compliance programme design for Germany subsidiaries in Poland in light of the revised thresholds. Where remote-working arrangements affect the employee headcount calculation across borders, the remote work framework under Polish labour law is directly relevant to the threshold assessment.

The Omnibus is still a proposal. The Stop-the-Clock directive is advancing faster and may be formally adopted by mid-2026. Companies should plan on the basis that the delay is real but that the substantive reporting obligation for in-scope entities is not going away.

Your company's specific position under the revised thresholds requires an individual assessment. Acting now – before the Omnibus text is finalised – preserves options that will close once the directive is transposed into Polish law.

If your company is above the 1,000-employee threshold or operates as part of a group that may consolidate into scope, we will map your obligations, review your existing compliance programme, and advise on the simplified ESRS framework: info@kordeckipartners.com.

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, whistleblower programme design, and AML advisory. 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.