A Kraków-based manufacturing company with 280 employees and annual revenue just above EUR 40 million receives a letter from its German parent requesting a full sustainability report by March 2026. The finance director searches Polish law for an answer. The rules are scattered across EU directives, Polish implementing legislation, and sector-specific guidelines – and the deadlines are already running.

The Corporate Sustainability Reporting Directive (CSRD) replaces the Non-Financial Reporting Directive and applies in Poland through the amended ustawa o rachunkowości (Accounting Act). Large public-interest entities with over 500 employees were required to report from the 2024 financial year. Large companies meeting two of three size thresholds – over 250 employees, EUR 50 million net turnover, or EUR 25 million total assets – must report from the 2025 financial year. Listed SMEs follow from 2026, with a voluntary opt-out until 2028.

This guide explains which Polish entities fall within scope, what the step-by-step reporting process looks like, what it costs, and where companies most often go wrong. Three business scenarios illustrate the rules in practice.

Which entities must comply with CSRD in Poland?

Polish law implements CSRD through amendments to the Accounting Act, supervised by the Ministry of Finance. The National Court Register (KRS) records company size data, and the Polish Financial Supervision Authority (KNF) oversees listed entities. The Financial Reporting Standards Committee (KRSR) provides interpretive guidance on European Sustainability Reporting Standards (ESRS) application in Poland.

Three waves of mandatory entry define the Polish rollout. First-wave entities – those already subject to non-financial reporting under the prior directive – entered the CSRD regime for the 2024 financial year. These are public-interest entities with more than 500 employees. Reports covering 2024 are due in 2025.

Second-wave entities enter from the 2025 financial year. A company falls into this wave when it meets at least two of three criteria: more than 250 employees on average during the year; net turnover exceeding EUR 50 million; or total balance-sheet assets above EUR 25 million. This wave captures a large share of mid-sized Polish capital companies, including subsidiaries of foreign groups.

The third wave covers listed SMEs on EU-regulated markets, small and non-complex credit institutions, and captive insurance undertakings. They report from 2026 but may opt out until 2028 – a two-year grace period that requires an active decision, not silence.

  • Public-interest entities with over 500 employees: reporting from 2024
  • Large companies meeting two of three size criteria: reporting from 2025
  • Listed SMEs and small financial institutions: reporting from 2026 (opt-out to 2028)
  • Non-listed SMEs: currently out of scope but subject to indirect pressure from value-chain requirements
  • Third-country subsidiaries with EU-listed parent: may fall within group reporting scope

One threshold deserves particular attention. The 250-employee figure is calculated as an average over the financial year, not a snapshot at year-end. A company that hires seasonally and averages 260 employees is in scope even if it employs fewer than 250 on 31 December.

What does the step-by-step CSRD reporting process look like?

The reporting process under CSRD is not a single document exercise. It involves a double materiality assessment, data collection across ESG reporting dimensions, application of ESRS standards, limited assurance by an accredited auditor, and filing within the statutory deadline. Companies that treat it as an annual report add-on typically miss the assurance timeline by six to eight weeks.

Step one is the double materiality assessment. The company must identify which sustainability topics are material from two perspectives: impact materiality (effects on people and environment) and financial materiality (effects on the company's finances). This assessment drives the entire report structure. It should be completed at least six months before the report filing date.

Step two covers data architecture. ESRS require disclosure across environmental, social, and governance topics. Data must be collected from internal systems, suppliers, and – where relevant – the value chain. Many Polish companies discover at this stage that their ERP systems do not capture the required data granularity. Retrofitting data collection mid-year is expensive; building it before the reporting period is not.

Step three is drafting the sustainability statement, which forms part of the management report (sprawozdanie z działalności). The statement must follow ESRS structure and include quantitative metrics, targets, and policy descriptions.

Step four is limited assurance. Polish law requires an accredited statutory auditor or audit firm to provide limited assurance on the sustainability statement. The assurance engagement typically takes eight to twelve weeks. Booking an auditor early – at least four months before the filing deadline – is not optional in a market where capacity is constrained.

We assisted a technology services company in the Mazowieckie region in completing its double materiality assessment and structuring its ESRS data architecture (autumn 2025). The project took fourteen weeks from kick-off to audit-ready draft.

What are the most common compliance mistakes under CSRD?

The most damaging mistakes are not technical errors in ESRS application. They are structural: starting too late, misidentifying scope, and underestimating assurance lead times. A company that begins its CSRD process in October for a December year-end report will not obtain limited assurance in time. The consequence is a late or non-compliant filing – and personal liability of board members under Polish corporate legislation for material misstatements in the management report.

Mistake one: treating CSRD as a communications exercise. Sustainability reports written by marketing teams without legal and financial oversight routinely fail ESRS disclosure requirements. ESRS are accounting standards, not press releases. They require the same rigour as financial statements.

Mistake two: ignoring value-chain obligations. CSRD does not limit reporting to the company's own operations. ESRS require disclosure on material impacts and risks across the value chain. A Polish manufacturer sourcing from lower-cost suppliers in Asia must assess and disclose those supply-chain risks. Failure to do so is not a minor omission – it is a gap that limited assurance will flag.

Mistake three: overlooking the link between CSRD and other compliance obligations. Compliance programme design for subsidiaries operating in Poland must now integrate ESG reporting obligations alongside AML, whistleblower compliance, and anti-corruption frameworks. Treating these as separate workstreams creates inconsistencies that auditors and regulators notice.

Mistake four: misapplying the SME opt-out. The opt-out available to listed SMEs until 2028 is not automatic. It requires the company to include a brief statement in its management report explaining why it has not prepared a sustainability statement. Companies that simply omit the statement without that explanation are non-compliant from day one.

How do three business scenarios illustrate the scope rules?

Abstract thresholds become clearer through concrete situations. The three scenarios below cover the most common queries we receive from Polish companies and foreign investors entering the Polish market.

Scenario one – Polish manufacturing subsidiary of a German group. A Silesian manufacturer employs 310 people, has EUR 55 million turnover, and EUR 20 million total assets. It meets two of the three size criteria (employees and turnover). It is a large company in scope from the 2025 financial year. Its German parent is already reporting under CSRD. The subsidiary must prepare its own sustainability statement and obtain limited assurance independently – group consolidation does not exempt a Polish subsidiary that meets the thresholds. For context on how German parent-subsidiary relationships interact with Polish compliance obligations, see our analysis of compliance programme design for Germany subsidiaries in Poland.

Scenario two – Polish IT services company, founder-owned. A Warsaw-based software house employs 180 people and has EUR 30 million turnover. It falls below all three size thresholds. It is not directly in scope. However, three of its largest clients are CSRD-in-scope companies that require supplier sustainability data under their own value-chain reporting obligations. The company faces indirect CSRD pressure without a direct legal obligation. Preparing a voluntary report aligned with ESRS – or at minimum a supplier questionnaire response framework – is commercially necessary even if legally optional.

Scenario three – Foreign investor acquiring a Polish target. A Dutch private equity fund acquires a Polish retail chain with 400 employees and EUR 80 million turnover. The target meets two size criteria and is in scope from 2025. The acquisition closes in April 2025. The new board inherits a CSRD obligation for a financial year already partially elapsed. Board members who fail to ensure compliant reporting face personal liability for management report deficiencies. This risk is material in due diligence and should be priced into the transaction. The broader personal exposure framework is analysed in our guide on board liability under Polish corporate law.

We supported a foreign investor's newly acquired subsidiary in Małopolska in completing a gap analysis and remediation roadmap within sixty days of transaction close (winter 2025). The board avoided a first-year filing deficiency.

What should companies prepare before the reporting deadline?

Preparation is the difference between a compliant filing and a board-level liability event. The checklist below reflects what an in-scope Polish company needs before its sustainability statement can go to limited assurance. Each item has a lead time. None can be compressed to zero.

  • Completed double materiality assessment with documented stakeholder input
  • Data collection framework aligned with applicable ESRS disclosure requirements
  • Internal governance sign-off: board resolution approving the sustainability reporting process
  • Engagement letter with an accredited statutory auditor for limited assurance – at least four months before filing
  • Legal review of the sustainability statement for consistency with the financial report and compliance programme disclosures

Cost expectations vary by company size and data readiness. A first-year CSRD project for a mid-sized Polish company typically involves legal and advisory fees in the range of PLN 80,000 to PLN 250,000, depending on complexity and the state of existing data systems. Limited assurance fees are additional and are quoted separately by audit firms. Companies that invest in reusable data infrastructure in year one reduce year-two costs materially.

Timeline discipline matters more than budget. A company that begins preparation in January for a December year-end report has twelve months. A company that begins in September has three – and limited assurance alone requires eight to twelve weeks of that window.

Specific situations require tailored analysis. If your company is approaching a CSRD threshold or has already crossed one without a reporting process in place, the window for compliant first-year filing is narrowing. To receive an expert assessment of your company's CSRD scope and readiness, contact info@kordeckipartners.com.

Frequently asked questions

Q: Does CSRD apply to a Polish limited liability company (spółka z ograniczoną odpowiedzialnością, sp. z o.o.) that is not listed on any exchange?

A: Yes, if the company meets two of the three size thresholds – more than 250 employees, EUR 50 million net turnover, or EUR 25 million total assets. Exchange listing is relevant only for the SME wave entering in 2026. A privately held sp. z o.o. that qualifies as a large company under the Accounting Act is in scope from the 2025 financial year regardless of its ownership structure.

Q: How long does a first-year CSRD project typically take, and what does it cost?

A: End-to-end, a first-year project for a mid-sized Polish company takes between nine and fourteen months if started from scratch. The double materiality assessment alone takes six to ten weeks. Legal and advisory fees typically range from PLN 80,000 to PLN 250,000. Limited assurance by a statutory auditor is priced separately and typically adds PLN 30,000 to PLN 80,000 depending on company size and data quality.

Q: Is it a common misconception that a Polish subsidiary is exempt from CSRD if its foreign parent is already reporting at group level?

A: It is one of the most frequent misconceptions we encounter. Group-level CSRD reporting by a parent company does not automatically exempt a Polish subsidiary that independently meets the size thresholds. The subsidiary must prepare its own sustainability statement and obtain its own limited assurance unless a specific consolidation exemption applies – and those exemptions have strict conditions that many subsidiaries do not satisfy. Legal advice on whether the exemption applies should be obtained before the reporting deadline, not after a filing is missed.

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 mandatory reporting obligations under Polish and EU law. 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.