On paper, the European Union's sustainability reporting framework looked settled. In practice, the Omnibus package and the accompanying Stop-the-Clock directive have redrawn the timeline and scope of the Corporate Sustainability Reporting Directive (CSRD) in ways that affect thousands of Polish companies. The changes are not cosmetic. They shift reporting obligations, raise thresholds, and defer deadlines – but they do not eliminate the underlying compliance duty for those who remain in scope.
The Stop-the-Clock directive, formally adopted by the European Parliament in April 2025, suspends the CSRD reporting obligation for large non-listed companies and listed small and medium-sized enterprises (SMEs) by two years. The Omnibus package simultaneously proposes raising the employee threshold from 250 to 1,000 workers, which would remove roughly 80 percent of previously in-scope Polish entities. Companies that remain in scope – primarily large listed groups and certain financial institutions supervised by the Polish Financial Supervision Authority (KNF) – must continue preparing their sustainability reporting infrastructure now, not after the dust settles.
This alert explains what changed, which Polish entities are still affected, and what immediate steps are required. Three questions structure the analysis: what the legislative shift actually means, who is now in or out of scope, and what boards and compliance teams must do before year-end 2026.
What did the Omnibus package and Stop-the-Clock actually change?
The Stop-the-Clock directive grants a two-year deferral to the second and third waves of CSRD reporters. Large non-listed companies that were due to report for financial year 2025 – filing in 2026 – now have until financial year 2027 at the earliest. Listed SMEs, originally scheduled for 2026, gain a corresponding extension. The first wave – large public-interest entities already reporting under the Non-Financial Reporting Directive (NFRD) – remains on schedule. These entities, overseen in Poland by the National Court Register (KRS) and the KNF, are not relieved by Stop-the-Clock.
The Omnibus package goes further. It proposes amending the CSRD itself by lifting the employee headcount threshold from 250 to 1,000. If adopted as proposed, only companies with more than 1,000 employees and either EUR 50 million in net turnover or EUR 25 million on the balance sheet would fall within the directive's mandatory scope. That is a structural narrowing. A Polish manufacturing group with 600 employees and EUR 60 million in revenue, previously in scope, would exit mandatory CSRD reporting entirely.
One important caveat: the Omnibus threshold amendments are still legislative proposals. They require co-decision between the European Parliament and the Council of the EU. Until transposition into Polish law – via amendment to the ustawa o rachunkowości (Accounting Act) – the current 250-employee threshold remains the operative domestic standard. Compliance teams should not treat the proposal as enacted law.
Which Polish companies are still in scope?
Scope now depends on which wave a company belongs to and whether the Omnibus thresholds have been formally adopted. Three categories warrant immediate attention. First, large public-interest entities already subject to NFRD – banks, insurers, listed companies with more than 500 employees – face no deferral and must comply with European Sustainability Reporting Standards (ESRS) for financial year 2024 reporting. Second, large listed companies on the Warsaw Stock Exchange (GPW) with between 250 and 1,000 employees gain the two-year deferral but should monitor the Omnibus threshold closely. Third, subsidiaries of non-EU groups with significant Polish operations may face indirect obligations through parent-level CSRD compliance, regardless of domestic headcount.
The AML and whistleblower compliance dimensions also shift here. Companies that exit mandatory CSRD scope still carry obligations under the Polish whistleblower protection law (enacted in June 2024) and under anti-money laundering regulations supervised by the General Inspector of Financial Information (GIIF). ESG reporting and internal compliance infrastructure overlap: a company that dismantles its sustainability reporting programme entirely may inadvertently weaken its whistleblower channel and AML controls. That is a compliance risk that boards should not ignore.
We secured a structural compliance review for a manufacturing client in Silesia (autumn 2025), identifying that the client's planned exit from CSRD scope did not relieve its whistleblower reporting obligations – saving the client from a potential enforcement gap. For foreign-owned subsidiaries, the interaction between parent-level CSRD obligations and Polish domestic law requires careful mapping. Our team assisted a Czech-owned subsidiary in Małopolska (spring 2026) in aligning its local compliance programme with group-level ESRS requirements – a process that took under six weeks once the scope analysis was complete.
What must boards and compliance teams do now?
Three immediate actions apply regardless of whether a company ultimately remains in mandatory CSRD scope. First, conduct a threshold audit. Map current employee headcount, turnover, and balance sheet figures against both the existing 250-employee threshold and the proposed 1,000-employee threshold. Document the analysis. If the Omnibus amendment is adopted, that documentation supports a defensible exit from mandatory reporting. If it is not adopted, the company is already prepared to comply.
What should that audit cover?
- Verified headcount figures as at the last financial year-end
- Consolidated turnover and balance sheet totals
- Listed or non-listed status on the GPW or other regulated markets
- Parent-company CSRD obligations that may cascade to Polish subsidiaries
- Existing whistleblower channel and AML programme status
Second, preserve the compliance infrastructure already built. Companies that invested in ESRS gap analyses, double materiality assessments, or data collection systems should not dismantle those systems. The two-year deferral is not an exemption. When reporting obligations resume – or when the Omnibus thresholds are finalised – companies that maintained their infrastructure will face a shorter, less costly path to compliance than those that stopped work entirely.
Third, review supply chain and contractual exposure. Large in-scope customers – particularly listed groups and financial institutions – will continue to request sustainability data from their suppliers under ESRS S1 and ESRS G1. A Polish SME that exits mandatory CSRD scope may still face contractual ESG reporting requirements from its principal customers. Ignoring those requirements risks losing supply chain positions, not just regulatory penalties. For guidance on structuring compliance programmes that address both domestic and cross-border obligations, see our analysis of compliance programme design for Cyprus subsidiaries in Poland and compliance programme design for Czech Republic subsidiaries in Poland. Where contractual disputes arise from ESG clause enforcement, the principles discussed in our guide on arbitration clauses for Polish contracts become directly relevant.
The complexity here is real. A company that misreads its scope – either over-investing in reporting it does not need or abandoning obligations it still carries – faces costs that are difficult to reverse. Personal liability of board members for compliance failures under Polish corporate legislation does not disappear because the EU amended a directive.
Your company's specific position under the Omnibus amendments requires a tailored scope analysis. Delaying that analysis until the legislative process concludes forfeits the preparation time that in-scope companies cannot afford to lose.
To receive an expert assessment of your CSRD scope and immediate compliance obligations, contact info@kordeckipartners.com. If your company is between 250 and 1,000 employees and currently preparing for CSRD – or has paused preparation on the assumption that the Omnibus thresholds are already law – we will map your exact position, identify residual obligations, and structure a proportionate compliance programme: info@kordeckipartners.com.
Frequently asked questions
Q: Does Stop-the-Clock mean our company no longer needs to report under CSRD at all?
A: Not necessarily. Stop-the-Clock defers the reporting obligation for second- and third-wave companies by two years. It does not eliminate the obligation. Companies already in the first wave – large public-interest entities under the Non-Financial Reporting Directive – remain on schedule. The deferral is a timeline adjustment, not an exemption from the directive's requirements.
Q: When will the Omnibus threshold change from 250 to 1,000 employees take effect in Poland?
A: The 1,000-employee threshold is a legislative proposal, not enacted law. It must complete the EU co-decision process and then be transposed into the Polish Accounting Act before it becomes operative. Until that transposition occurs, the current 250-employee threshold applies under Polish law. Companies should not plan their compliance programmes on the assumption that the proposal has already passed.
Q: If we exit CSRD scope, do our whistleblower and AML obligations also fall away?
A: No. Whistleblower protection obligations under the Polish whistleblower law and AML duties supervised by the General Inspector of Financial Information are independent of CSRD scope. A company that exits mandatory sustainability reporting still carries those obligations in full. Dismantling ESG-related compliance infrastructure without reviewing its overlap with whistleblower and AML programmes creates enforcement exposure that is entirely separate from CSRD.
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 regulatory change management. We work with Polish entrepreneurs, foreign investors, and in-house legal teams navigating sustainability reporting obligations and internal compliance programme design. 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.