CSRD Omnibus and Stop-the-Clock – what changes for Poland

On paper, the European Union's sustainability reporting framework looked settled. In practice, the Omnibus package and the Stop-the-Clock directive have redrawn the timeline for thousands of companies operating in Poland. Businesses that built compliance roadmaps around the original CSRD schedule now face a choice: pause and reassess, or press ahead and risk misallocating resources.

The Stop-the-Clock directive, formally adopted in spring 2025, postpones the CSRD reporting obligation by two years for companies in waves two and three. For most Polish and foreign-owned companies outside the first wave, the earliest mandatory ESG reporting year shifts from 2025 to 2027. The Omnibus package – a broader legislative proposal from the European Commission – goes further, proposing to narrow the scope of CSRD to companies with more than 1,000 employees and to simplify the required content of sustainability reports. Both measures are still moving through the legislative process, but their practical impact on Polish compliance planning is immediate.

This guide walks through what has changed, who is affected in Poland, what the revised timeline looks like, and where the genuine compliance risks now sit. Three business scenarios – a Polish manufacturer, a Warsaw-based IT company, and a foreign investor with a Polish subsidiary – illustrate how the changes apply in practice.

What did the original CSRD schedule require?

The Corporate Sustainability Reporting Directive (CSRD) replaced the earlier Non-Financial Reporting Directive and expanded both the scope of reporting companies and the depth of required disclosures. Under the original timetable, the obligation rolled out in three waves. Large public-interest entities with more than 500 employees – largely listed companies and banks – were required to report for the financial year 2024. Wave two covered other large companies meeting two of three size criteria: more than 250 employees, net turnover above EUR 40 million, or balance sheet above EUR 20 million. They were to report for 2025. Wave three extended obligations to listed small and medium-sized enterprises (SMEs), with a reporting year of 2026.

The National Court Register (KRS) in Poland is the reference point for determining corporate form and size. Companies filing annual accounts with the KRS had to assess whether they crossed the relevant thresholds. The Polish Financial Supervision Authority (KNF) retained oversight of listed entities, while the Office of the Financial Ombudsman and sector regulators monitored compliance in supervised industries. Practically, wave two captured a significant portion of Polish capital groups and subsidiaries of international groups operating locally.

Reports had to comply with the European Sustainability Reporting Standards (ESRS), covering environmental, social, and governance topics through a double materiality lens. That lens requires companies to assess both how sustainability issues affect the business and how the business affects society and the environment. For many Polish companies, building that assessment from scratch represented a project lasting six to twelve months.

How do Stop-the-Clock and the Omnibus package change the rules?

Stop-the-Clock is already law. The directive postpones wave two obligations by two years, moving the first mandatory reporting year from 2025 to 2027. Wave three – listed SMEs – is similarly deferred, with their reporting year shifting to 2028. Wave one companies (large public-interest entities) remain on the original schedule and report for 2024 as planned. The postponement gives affected companies two additional preparation years, but it does not eliminate the obligation.

The Omnibus package is a proposal, not yet enacted. It proposes to raise the employee threshold to 1,000, which would remove wave two companies with between 250 and 999 employees from mandatory CSRD scope entirely. If adopted in its current form, that change would shrink the population of obligated Polish companies dramatically. The Omnibus also proposes to simplify the ESRS content requirements and to narrow the value-chain due diligence obligations under the related Corporate Sustainability Due Diligence Directive (CS3D).

Three practical consequences follow for Polish companies right now. First, any company in wave two that has not yet started CSRD preparation has breathing room – but not indefinitely. Second, companies near the 1,000-employee threshold face genuine uncertainty: they may fall out of mandatory scope, or they may not, depending on final Omnibus text. Third, companies that are subsidiaries of non-EU groups may still face parent-level reporting requirements regardless of Polish law developments. The Polish Agency for Enterprise Development (PARP) has published guidance noting that voluntary reporting can support financing access even where mandatory obligations are deferred.

What is the revised compliance timeline for Polish companies?

The working timeline now looks like this. Wave one companies – large public-interest entities above 500 employees, listed on the Warsaw Stock Exchange (GPW) or other regulated markets – report for financial year 2024, with reports due in 2025. No change applies to them. Wave two companies (other large entities above 250 employees) report for financial year 2027 under Stop-the-Clock, meaning their first CSRD report is due in 2028. Wave three listed SMEs report for 2028, with reports due in 2029.

If the Omnibus package is adopted and the 1,000-employee threshold becomes law, companies between 250 and 999 employees exit mandatory scope entirely. That outcome is not guaranteed. The legislative process in the European Parliament and Council could modify the threshold, add sector-specific carve-outs, or introduce a voluntary simplified standard. Companies should treat the Omnibus as a possible relief, not a confirmed exemption.

For planning purposes, a 12-month implementation window remains realistic for companies starting from zero. That means a wave two company targeting 2027 reporting should begin a gap analysis no later than early 2026. Key preparation steps include: appointing an internal ESG reporting owner, conducting a double materiality assessment, mapping data availability across the organisation, and engaging an accredited third-party assurance provider. Limited assurance – the required standard for early CSRD reports – typically requires three to four months of auditor engagement before the reporting period ends.

• Appoint an ESG reporting owner with board-level sponsorship
• Complete a double materiality assessment before data collection begins
• Map data gaps against ESRS requirements and build collection processes
• Engage a limited assurance provider at least six months before report sign-off
• Monitor Omnibus progress quarterly and adjust scope assumptions accordingly

Which Polish companies face the highest compliance risk?

The companies most exposed are those that assumed the Omnibus would pass quickly and suspended all CSRD preparation. If the Omnibus is delayed, amended, or rejected, those companies will face a compressed timeline with no margin. A wave two company that waits until 2026 to begin preparation and then discovers the 1,000-employee threshold was not adopted is in a difficult position. Personal liability of senior managers is not the primary enforcement mechanism under CSRD – but reputational damage, loss of financing access, and contractual penalties from customers requiring supply-chain ESG data are all real consequences.

We obtained alignment of a sustainability reporting framework for a manufacturing client in the Mazowieckie region (autumn 2025), helping them avoid a six-month delay caused by an incomplete double materiality assessment. The client had assumed internal HR and financial data would be sufficient; in practice, scope 3 emissions data from suppliers required a separate collection project that added three months to the timeline.

Foreign investors with Polish subsidiaries face a second layer of complexity. A German parent subject to CSRD wave one may require its Polish operating subsidiary to provide ESRS-aligned data regardless of whether the Polish entity itself is in mandatory scope. That data request will not wait for Omnibus clarity. Similarly, companies with Swiss or Italian parent structures – where the parent is within CSRD scope – should review their group reporting obligations carefully. For guidance on compliance programme design in those contexts, see our analysis of compliance programme design for Switzerland subsidiaries in Poland and compliance programme design for Italy subsidiaries in Poland.

Three scenarios illustrate the risk distribution. A Polish manufacturer with 400 employees sits in wave two and currently falls below the proposed Omnibus threshold. It should monitor legislative progress but maintain a readiness file. A Warsaw IT company with 1,200 employees remains in scope under both the current law and the Omnibus proposal. It should be actively building ESRS data infrastructure now. A foreign investor holding a Polish subsidiary with 300 employees may escape Polish mandatory scope but will still supply group-level ESG data – making voluntary compliance effectively mandatory in practice.

Whistleblower compliance and AML frameworks intersect with ESG reporting in ways that are often overlooked. The social pillar of ESRS requires disclosure of internal reporting channels, speak-up culture, and anti-corruption measures. Companies that have not yet implemented the whistleblower directive (transposed into Polish law in 2024) will find that gap surfaced directly in their CSRD report. A compliance lawyer in Warsaw advising on ESG reporting will typically flag this connection in the first review meeting.

To receive an expert assessment of your company's CSRD readiness position, contact info@kordeckipartners.com.

Frequently asked questions

Q: Does the Stop-the-Clock directive automatically exempt my company from CSRD obligations?

A: No. Stop-the-Clock postpones the obligation – it does not remove it. Wave two companies must still report under CSRD, with the first reporting year now being 2027 rather than 2025. The Omnibus package separately proposes a scope reduction, but that proposal has not yet been enacted. Companies should treat the two measures as distinct and monitor both.

Q: How long does it realistically take to prepare a first CSRD report from scratch?

A: For a company starting with no prior ESG data infrastructure, a realistic preparation timeline is 12 to 18 months. The double materiality assessment alone typically takes two to three months when done properly. Engaging an assurance provider, building data collection systems, and drafting the report in ESRS format adds further time. Starting in early 2026 gives a wave two company adequate runway for a 2027 reporting year.

Q: If the Omnibus raises the threshold to 1,000 employees, does my company still need to do anything?

A: Possibly. Even if your company exits mandatory CSRD scope, three situations can create de facto obligations. First, if your parent company is in scope, it will require ESG data from your entity as part of group reporting. Second, major customers subject to CSRD may request supply-chain sustainability data under their own value-chain disclosure obligations. Third, financing institutions – banks, bond investors, private equity – increasingly require ESG data as a condition of credit or investment. Voluntary alignment with a simplified reporting standard may protect access to capital even without a legal mandate. For questions about how expert assessments are used in compliance proceedings, see our overview of expert witnesses in Polish court proceedings.

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. 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.