A Kraków-based manufacturing group with 280 employees spent eighteen months building its sustainability reporting infrastructure. Then, in early 2025, the European Commission proposed the Omnibus package – and the rules changed. The question now facing that company, and hundreds like it across Poland, is not whether to comply with the Corporate Sustainability Reporting Directive (CSRD) but when, and to what reduced standard.

The CSRD Omnibus package proposes to narrow the scope of mandatory sustainability reporting, raising the employee threshold from 250 to 1,000 and delaying application dates for wave-two and wave-three companies by two years under the so-called Stop-the-Clock mechanism. For Polish companies already within scope, the changes reduce the number of mandatory disclosure topics and soften the double-materiality assessment. The Polish transposition framework, overseen by the Komisja Nadzoru Finansowego (Polish Financial Supervision Authority, KNF) and reported to the Krajowy Rejestr Sądowy (National Court Register, KRS), will need to be updated once the Omnibus directive is formally adopted.

This guide walks through the practical implications step by step: which Polish companies are now affected, what the revised timeline looks like, where the compliance burden shrinks and where it remains unchanged, and how three business scenarios – a manufacturer, an IT firm, and a foreign investor – should respond. Each section ends with a concrete action point.

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

The original CSRD divided companies into three waves. The Omnibus proposal restructures that division sharply. Under the revised threshold, a company must exceed 1,000 employees – not 250 – to fall within mandatory scope. That single change removes an estimated majority of Polish companies that had been preparing for wave-two obligations.

Polish large public-interest entities (PIEs) supervised by the KNF – listed companies, banks, and insurers – remain in wave one and are unaffected by Stop-the-Clock. They were required to report from financial year 2024. For them, the Omnibus changes the content of reporting, not the start date. The Urząd Komisji Nadzoru Finansowego (Office of the Polish Financial Supervision Authority, UKNF) has confirmed that wave-one entities should continue preparing under current rules pending formal adoption of the Omnibus directive.

Wave-two companies – large non-PIE companies that met the 250-employee threshold – were due to report from financial year 2025. Stop-the-Clock proposes to defer that obligation by two years, to financial year 2027. Polish companies in this bracket now have a window of approximately 24 months before their first CSRD report is due. That window is not a holiday. It is time to redesign a leaner compliance programme aligned to the reduced disclosure set.

  • Wave one (PIEs, listed): reporting from FY 2024 – unchanged
  • Wave two (large non-PIE, formerly 250+ employees): deferred to FY 2027
  • Wave three (listed SMEs): deferred to FY 2028 at the earliest
  • Companies dropping below 1,000 employees: outside mandatory scope
  • Voluntary reporting: permitted and increasingly expected by lenders

One misconception is widespread: removal from mandatory scope does not mean removal from reporting pressure. Banks operating under the Europejski Bank Centralny (European Central Bank, ECB) supervisory framework will continue to request ESG data from their SME borrowers through value-chain enquiries. A Polish mid-size manufacturer supplying a DAX-listed group will still receive sustainability questionnaires. The threshold change shifts legal obligation; it does not shift commercial reality.

What does the Stop-the-Clock mechanism actually change?

Stop-the-Clock is a legislative mechanism – formally a standalone amending directive – that inserts a two-year delay into the CSRD application dates for wave-two and wave-three companies. It does not amend the substantive content of CSRD. It simply moves the clock. The European Parliament voted to approve the Stop-the-Clock directive in April 2025, and member states are expected to transpose it within a short window, likely by mid-2025.

Poland's transposition obligation is straightforward. The Polish Ministry of Finance, which led the original CSRD transposition through an amendment to the Ustawa o rachunkowości (Accounting Act), must pass a further amendment reflecting the new dates. Until that amendment is enacted, Polish companies should treat the two-year deferral as politically confirmed but not yet legally binding. Acting as though Stop-the-Clock is already law – and dismantling compliance programmes accordingly – is premature and carries risk.

The Omnibus package goes further than Stop-the-Clock alone. It proposes three substantive changes that will apply once the full Omnibus directive is adopted – a process expected to conclude no earlier than late 2025 or early 2026:

  • Reduction of mandatory European Sustainability Reporting Standards (ESRS) disclosure points by roughly 70%
  • Simplification of the double-materiality assessment methodology
  • Narrowing of value-chain due diligence obligations under the linked Corporate Sustainability Due Diligence Directive (CSDDD)

For a compliance lawyer advising Warsaw-based clients, the practical consequence is a two-stage programme. First, confirm whether the client is within revised scope. Second, monitor the Omnibus adoption timeline and update the reporting architecture when the directive enters Polish law. Dismantling existing data-collection systems before adoption is inadvisable. Those systems will be needed – in a lighter form – from 2027 onward.

How should three business scenarios respond?

Abstract legal analysis helps less than concrete scenario mapping. The three scenarios below cover the business types most frequently encountered in Polish compliance practice: a manufacturing company, an IT services firm, and a foreign investor's Polish subsidiary. Each scenario highlights where the Omnibus changes create genuine relief and where obligations persist.

Manufacturing company, 600 employees, Mazowieckie region. This company fell squarely within wave-two scope under the original CSRD. Under the revised 1,000-employee threshold, it exits mandatory scope entirely. However, its two largest customers are DAX-listed groups that will remain in wave-one scope and will pass sustainability questionnaires down the supply chain. We assisted a comparable manufacturer in the Mazowieckie region in designing a voluntary ESG data framework calibrated to customer questionnaire requirements rather than full ESRS compliance (autumn 2025). The cost of that framework was roughly 40% of a full CSRD programme. The company retains the option to scale up if it crosses the 1,000-employee threshold through organic growth or acquisition.

IT services company, 1,400 employees, Kraków. This company remains above the revised threshold and stays in wave-two scope, now deferred to FY 2027. It has 24 months to complete a double-materiality assessment, select applicable ESRS topics, and build data-collection processes. The Omnibus reduction of mandatory ESRS disclosures means the company can focus its programme on material topics – likely Governance, Own Workforce, and Climate – rather than the full 12-topic ESRS set. A phased implementation plan, beginning with governance and workforce data in 2025 and adding environmental metrics in 2026, is achievable within that window.

German investor's Polish subsidiary, 350 employees, Lower Silesia. The subsidiary drops below the revised 1,000-employee threshold and exits mandatory Polish CSRD scope. However, the German parent remains subject to German transposition of CSRD and will consolidate the Polish subsidiary's sustainability data into its own group report. The subsidiary must provide data to the parent regardless of its own reporting status. We secured a clear data-flow protocol for a German investor's Polish entity in Lower Silesia, reducing the internal reporting burden by approximately 30% compared to a standalone CSRD programme (spring 2026). The key insight: the subsidiary's obligation runs to the parent, not to Polish regulators.

What steps should in-scope Polish companies take now?

For companies that remain in scope – primarily wave-one PIEs and larger companies above 1,000 employees – the Omnibus changes require a programme review rather than a programme rebuild. The double-materiality assessment already completed does not need to be discarded. It needs to be recalibrated against the reduced ESRS disclosure set once the Omnibus directive is formally adopted.

The first concrete step is a scope confirmation exercise. A company should map its employee count, balance-sheet total, and net turnover against both the current and proposed thresholds. If the company is borderline – between 800 and 1,200 employees – it should model both scenarios and prepare a contingency plan. Threshold calculations under Polish accounting law are based on the average number of full-time equivalent employees during the financial year, not headcount on a single date.

The second step is timeline mapping. Companies in scope should work backward from the FY 2027 reporting date. A credible programme requires at least 18 months of data collection before the first report. That means data-collection systems must be operational by January 2026 at the latest. For AML and whistleblower compliance systems already in place, the data architecture often overlaps with ESG governance data requirements – a point that reduces implementation cost if planned carefully.

What to prepare – a practical checklist:

  • Confirm revised employee threshold status and document the calculation
  • Map existing data-collection systems against reduced ESRS disclosure requirements
  • Identify value-chain data requests from customers or parent companies
  • Assign internal responsibility for sustainability reporting to a named function
  • Set a programme review date tied to Omnibus adoption – expected Q1 2026

For companies exiting mandatory scope, the third step is a deliberate decision on voluntary reporting. Voluntary CSRD-aligned reporting is increasingly referenced in bank financing documentation, public procurement criteria, and investor due-diligence questionnaires. A company that builds a lightweight voluntary framework now – covering governance, workforce, and one environmental metric – is better positioned than one that waits for the next regulatory cycle. The investment is measured in weeks of professional time, not months.

For cross-border compliance structures, the interaction between CSRD, CSDDD, and existing AML frameworks deserves specific attention. A compliance programme designed for a Slovak subsidiary operating in Poland – where the reporting entity sits in a different member state – raises questions about which national transposition governs. Readers advising on those structures may find the analysis at compliance programme design for Slovakia subsidiaries in Poland directly relevant.

For companies with technology-sector operations, the intersection of CSRD governance disclosures with IP protection strategy is increasingly material. Governance disclosures may require transparency about data-handling and technology asset management that overlaps with IP strategy. The framework discussed at IP protection strategy for Poland tech companies addresses that overlap. Similarly, French-group subsidiaries in Poland face a dual-layer obligation – French parent CSRD scope plus Polish transposition – and the approach set out at compliance programme design for France subsidiaries in Poland provides a workable model.

The single most common mistake we see is treating the Omnibus deferral as an exemption. It is not. A company that stops all sustainability reporting preparation in 2025 and resumes in 2026 will face a compressed timeline, higher implementation costs, and the risk of incomplete data for the first reporting year. The 24-month window is most valuable when used, not when it is simply counted down.

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

Frequently asked questions

Q: Our company had 260 employees when the original CSRD was transposed. We are now at 280. Do we still need to report?

A: Under the Omnibus proposal, the mandatory threshold rises to 1,000 employees. A company with 280 employees would exit mandatory scope entirely, provided the Omnibus directive is formally adopted and transposed into Polish law before your first reporting date. Until that transposition occurs, the current 250-employee threshold remains technically in force under the Polish Accounting Act. You should monitor the Polish legislative process and maintain a lightweight data-collection capability as a precaution. The expected transposition window is late 2025 to early 2026.

Q: How much does a CSRD compliance programme cost for a mid-size Polish company?

A: Costs vary significantly depending on existing data infrastructure, the number of applicable ESRS topics, and whether third-party assurance is required. A programme covering three to four material ESRS topics for a company with 1,000 to 1,500 employees typically requires between 150 and 400 hours of professional advisory time, plus internal implementation costs. The Omnibus reduction in mandatory disclosure points may reduce that range by 30 to 40% compared to a full-scope programme. Companies that already have AML compliance and whistleblower reporting systems in place can often reuse that governance infrastructure, reducing cost further.

Q: Does Stop-the-Clock affect the obligation to respond to value-chain sustainability questionnaires from our customers?

A: No. Stop-the-Clock defers the legal obligation to publish a CSRD-compliant sustainability report. It has no effect on contractual obligations arising from supply agreements, bank financing covenants, or public procurement requirements that reference ESG data. A Polish supplier to a large European group will continue to receive sustainability questionnaires regardless of its own regulatory status. The practical advice is to maintain data-collection capacity sufficient to answer those questionnaires, even if you are outside mandatory reporting scope.

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 navigating the evolving European sustainability regulatory framework. 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.