A mid-sized Polish manufacturing company with 280 employees and EUR 52 million in annual revenue receives a questionnaire from its German parent. The parent needs sustainability data for its own Corporate Sustainability Reporting Directive (CSRD) disclosure. The Polish subsidiary's finance director asks a simple question: does our company have to comply directly, or only feed data upward? The answer depends on size, ownership structure, and the reporting year – and getting it wrong forfeits access to financing from lenders who now screen ESG disclosures before approving credit lines.
CSRD reporting obligations in Poland apply in three successive waves, starting with large public-interest entities for financial year 2024, expanding to other large companies for 2025, and reaching listed SMEs by 2026. A company is "large" under Polish corporate legislation if it exceeds two of three thresholds: 250 employees, EUR 40 million net turnover, or EUR 20 million in total assets. Non-compliance does not merely trigger a fine – it can disqualify a company from EU-funded procurement and ESG-linked credit facilities, consequences that are difficult to reverse once a reporting cycle has passed.
This guide explains the threshold tests, the reporting timeline, the procedural steps required under Polish law, and the three most common mistakes companies make when self-assessing their obligations. It also addresses how the obligation flows through group structures – a point that trips up both Polish subsidiaries of foreign groups and Polish parent companies with EU subsidiaries.
What is CSRD and how has it been implemented in Poland?
The Corporate Sustainability Reporting Directive replaced the earlier Non-Financial Reporting Directive (NFRD) and materially broadened the scope of mandatory ESG reporting across the European Union. In Poland, the directive was transposed through amendments to the ustawa o rachunkowości (Accounting Act) and related provisions governing the National Court Register (KRS). The Polish Financial Supervision Authority (KNF) oversees compliance for entities within the financial sector, while the Financial Reporting Department of the Ministry of Finance coordinates broader implementation. The National Securities Exchange Commission – now operating under KNF – applies additional scrutiny to listed entities.
The directive introduces the European Sustainability Reporting Standards (ESRS) as the mandatory framework for preparing sustainability statements. These standards cover environmental, social, and governance topics, including climate change, biodiversity, workforce conditions, and anti-corruption. Polish companies subject to CSRD must integrate the sustainability statement into their management report – it is not a separate standalone document. This integration requirement has practical consequences: the management report must be audited, and the sustainability data within it is subject to limited assurance from a statutory auditor registered with the Polish Chamber of Statutory Auditors (PIBR).
One detail that surprises many clients: CSRD does not require a company to perform well on ESG metrics. It requires disclosure of material impacts, risks, and opportunities. A company with poor environmental performance must report that performance accurately. Misrepresentation, not poor performance, is the regulatory breach.
Which companies must comply in Poland, and when?
The obligation applies in three waves. Wave one covers large public-interest entities (PIEs) – listed companies, banks, and insurers with more than 500 employees – for financial year 2024, with reports due in 2025. Wave two covers all other large companies (exceeding two of the three size thresholds above) for financial year 2025, with reports due in 2026. Wave three covers listed SMEs, small and non-complex credit institutions, and captive insurance undertakings for financial year 2026, with reports due in 2027. Non-listed SMEs may voluntarily adopt the simplified ESRS for SMEs framework.
The threshold test is applied at the balance sheet date of the preceding financial year. A company that crossed the "large" threshold in 2024 falls into wave two. A company that crossed it only in 2025 may not be captured until the following cycle. This timing matters enormously for companies near the boundary. (The test is assessed on a two-consecutive-year basis under Polish accounting law, mirroring the approach used for statutory audit triggers.)
- Wave 1 – PIEs with 500+ employees: FY 2024 reports
- Wave 2 – All large companies: FY 2025 reports
- Wave 3 – Listed SMEs: FY 2026 reports
- Voluntary SME framework: available from FY 2026 onward
We advised a logistics holding company in the Mazowieckie region (autumn 2025) that had restructured its group by splitting a single legal entity into three subsidiaries, each falling below the threshold individually. The restructuring was commercially motivated, but it also deferred CSRD obligations by at least one reporting cycle – a legitimate outcome, provided the restructuring has genuine business substance and is not a purely artificial arrangement.
How does group structure affect the reporting obligation?
Group structures introduce a layer of complexity that the size thresholds alone do not resolve. A Polish subsidiary of a foreign parent may be exempt from preparing its own CSRD-compliant sustainability statement if it is included in the consolidated sustainability report of its parent company. The exemption applies when the parent's consolidated report is prepared in accordance with CSRD or equivalent standards, and when the Polish subsidiary discloses the parent's report and its own inclusion in that report in the KRS filing.
This exemption is frequently misunderstood. It does not exempt the subsidiary from data collection. The parent's consolidated report draws on data reported upward by subsidiaries. A Polish subsidiary that fails to maintain adequate ESG data at entity level will block the parent's ability to consolidate accurately – creating a group-level compliance failure, not just a local one. The practical implication: even exempt subsidiaries need internal ESG data governance.
For Polish parent companies with EU subsidiaries, the reverse applies. The Polish parent must prepare a consolidated sustainability statement covering all subsidiaries above the threshold. This requires establishing a group-wide data collection protocol, agreeing on reporting perimeters, and aligning on double materiality assessment methodology. For guidance on structuring compliance programmes across group entities, see our analysis of compliance programme design for Germany subsidiaries in Poland.
One cross-border scenario worth flagging: a Polish company with a German subsidiary that is itself a PIE. The German subsidiary may have its own wave-one obligation. If the Polish parent's consolidated report is not yet required, both entities must independently assess their obligations. Coordination between the two legal teams – and between their respective statutory auditors – is essential from at least 18 months before the first reporting deadline.
What are the procedural steps and what do they cost?
Preparing a CSRD-compliant sustainability statement involves six distinct steps. First, the company conducts a double materiality assessment – identifying which sustainability topics are material from both an impact perspective (the company's effect on society and environment) and a financial perspective (sustainability risks and opportunities affecting the company's financial position). This assessment drives the entire report structure and determines which ESRS disclosure requirements apply. Skipping or shortcutting this step is the most common – and most consequential – mistake.
Second, the company maps its existing data sources against the required ESRS datapoints. Many companies discover at this stage that they lack baseline data on Scope 3 greenhouse gas emissions, supply chain labour conditions, or board diversity metrics. Closing these gaps typically takes six to twelve months. Third, the company drafts the sustainability statement in the format required by the ESRS, integrating it into the management report. Fourth, the statutory auditor performs limited assurance – a lower standard than a full audit, but still requiring documented evidence for each material disclosure.
- Double materiality assessment: 4–8 weeks with external support
- Data gap analysis and closure: 6–12 months
- Drafting the sustainability statement: 6–10 weeks
- Limited assurance engagement: 4–6 weeks
- KRS filing of the management report: within the statutory deadline post-year-end
Cost estimates vary widely. For a mid-sized Polish company preparing its first CSRD report, total external costs – including legal, sustainability advisory, and audit fees – typically range from PLN 150,000 to PLN 500,000. Companies that invest in ESG data infrastructure in year one tend to reduce costs significantly in subsequent cycles. For context on how ESG obligations interact with supply chain relationships, our guide on ESG due diligence in supply chains – Polish perspective addresses the downstream contractual implications.
To receive an expert assessment of your company's CSRD readiness position, contact info@kordeckipartners.com.
What are the three most common mistakes – and how do they foreclose options?
The first mistake is assuming that a company below the 500-employee threshold is automatically outside the scope. The wave-two threshold is 250 employees – not 500. A company with 260 employees, EUR 45 million turnover, and EUR 22 million in assets exceeds two of the three criteria and falls squarely into wave two. Missing this assessment forfeits the 12 to 18 months of preparation time that a well-run compliance project requires.
The second mistake is treating CSRD as a reporting exercise rather than a governance exercise. The ESRS require companies to describe their policies, targets, and due diligence processes – not merely their outcomes. A company that has no formal climate transition plan, no supplier code of conduct, and no whistleblower compliance mechanism will not be able to produce a compliant report simply by collecting data. Building the underlying governance structures takes time. Waiting until the reporting deadline approaches makes the gap impossible to close in a single cycle.
The third mistake is underestimating the audit interface. Limited assurance is not a box-ticking exercise. Statutory auditors registered with PIBR are required to challenge unsupported disclosures and can qualify the assurance opinion. A qualified opinion on the sustainability statement is a public document filed with the KRS and visible to counterparties, lenders, and public procurement authorities. We secured a reversal of an adverse preliminary assurance finding for a retail client in the Silesia region (spring 2026) by reconstructing the evidentiary basis for their Scope 2 emissions disclosures – but that reconstruction required three weeks of intensive work that could have been avoided with proper documentation from the outset.
A fourth issue – less a mistake than a missed opportunity – involves the interaction between CSRD disclosures and financing. Banks and private equity investors are increasingly using CSRD sustainability statements as inputs to ESG-linked loan pricing. Companies that produce high-quality, well-evidenced disclosures may qualify for lower interest margins. Conversely, companies that file late or produce qualified reports may find that ESG-linked financing options close before they can be accessed.
Frequently asked questions
Q: Our company just missed the "large" threshold in 2024 but may cross it in 2025. When exactly does the obligation attach?
A: Under Polish accounting law, the threshold is assessed at the balance sheet date. If your company exceeds two of the three criteria (250 employees, EUR 40 million turnover, EUR 20 million assets) at the close of two consecutive financial years, the reporting obligation attaches for the financial year following the second qualifying year. A company that first crosses the threshold at the end of 2025 would typically be subject to the obligation from financial year 2026. You should begin preparation at least 18 months before the first reporting year to allow time for data gap closure and governance development.
Q: Can a Polish subsidiary rely entirely on its EU parent's consolidated CSRD report and do nothing locally?
A: The exemption from preparing a standalone sustainability statement is available if the parent's consolidated report covers the subsidiary and is prepared under CSRD or equivalent standards. However, "doing nothing locally" is a misconception that creates serious risk. The subsidiary must still collect and transmit ESG data to the parent, maintain documentation supporting that data, and disclose the exemption in its own KRS filing. Failure to maintain local data governance means the parent's consolidated report may contain unverified or inaccurate data – which is a compliance failure at group level, not just a local administrative gap.
Q: How does CSRD interact with AML and whistleblower compliance obligations?
A: CSRD requires companies to describe their governance mechanisms for identifying and addressing material sustainability risks, which includes anti-corruption policies and whistleblower compliance channels. A company that already has a functioning AML programme and a whistleblower mechanism compliant with Polish whistleblower protection law will find those structures directly usable in its CSRD governance disclosures. Companies that lack these mechanisms face a dual compliance gap: they must address both the underlying legal obligation and the CSRD disclosure requirement simultaneously. For companies structuring group-level compliance frameworks, our analysis of dividend distribution rules for Polish companies at this link illustrates how governance decisions at subsidiary level interact with group financial reporting.
Your company's specific position – whether it sits just above or below the threshold, whether it is part of a group, and how mature its existing ESG data infrastructure is – determines which preparation steps are urgent and which can be sequenced. These distinctions are material and time-sensitive.
For a tailored strategy on CSRD compliance preparation, including threshold assessment, double materiality scoping, and audit-readiness review, reach out to 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, sustainability reporting, and corporate governance. We work with Polish entrepreneurs, foreign investors, and in-house legal teams navigating CSRD, ESRS, and related EU sustainability obligations. 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.