On paper, the Corporate Sustainability Reporting Directive looks like a straightforward extension of existing non-financial disclosure rules. In practice, determining whether your Polish entity falls within scope – and by which deadline – involves layered thresholds, transposition quirks, and reporting obligations that differ materially depending on company size, listing status, and group structure.

The Corporate Sustainability Reporting Directive (CSRD) replaces the Non-Financial Reporting Directive (NFRD) and introduces mandatory sustainability reporting under the European Sustainability Reporting Standards (ESRS). In Poland, the Directive was transposed into national law through amendments to the ustawa o rachunkowości (Accounting Act) and related legislation. Compliance timelines run in four waves between 2024 and 2028, with the first wave covering large public-interest entities already subject to NFRD obligations.

This guide explains each threshold in sequence, maps the four reporting waves to specific Polish entity types, identifies the most common structural traps, and sets out a practical preparation checklist. Three business scenarios – a Warsaw-based manufacturer, a mid-size IT company, and a German investor's Polish subsidiary – illustrate how the rules apply in concrete situations.

What is CSRD and how was it transposed into Polish law?

CSRD is an EU directive that fundamentally rewrites the rules on corporate sustainability disclosure. It expands the scope of mandatory reporting, introduces the double-materiality principle, and requires assurance of sustainability statements. Understanding the Polish transposition framework is the starting point for any compliance assessment.

Poland implemented CSRD through amendments to the Accounting Act and the ustawa o ofercie publicznej (Public Offering Act). The National Court Register (Krajowy Rejestr Sądowy, KRS) remains the reference point for determining entity classification. The Polish Financial Supervision Authority (Komisja Nadzoru Finansowego, KNF) oversees listed entities subject to the earliest deadlines. The Ministry of Finance (Ministerstwo Finansów) issued supplementary guidance on the interaction between CSRD and existing Polish financial reporting obligations.

ESRS – the European Sustainability Reporting Standards – sit at the heart of the new framework. They cover environmental, social, and governance topics across twelve thematic standards. Polish companies must apply ESRS when preparing their sustainability statements, which form part of the management report (sprawozdanie z działalności). This integration into the management report is a deliberate design choice: sustainability data sits alongside financial data, subject to the same audit-trail discipline.

The double-materiality principle deserves particular attention. A topic is material if it affects the company's financial performance (financial materiality) or if the company's activities affect society and the environment (impact materiality). Polish companies accustomed to NFRD's single-materiality lens will need to expand their assessment methodology significantly. Failure to conduct a proper double-materiality assessment is one of the most common errors we see at the pre-implementation stage.

Which Polish entities must comply – and when?

CSRD rolls out in four waves. Each wave has a distinct entry threshold. The wave you fall into determines your first reporting year, which in turn determines the financial year for which you must collect data and the calendar year in which you publish your first CSRD-compliant report.

Wave 1 covers large public-interest entities (duże jednostki zainteresowania publicznego) already subject to NFRD, with more than 500 employees. These entities reported under CSRD rules for the financial year 2024, meaning their first CSRD report was published in 2025. This group includes Warsaw Stock Exchange (Giełda Papierów Wartościowych, GPW) blue-chip issuers, large credit institutions, and insurance undertakings meeting the employee threshold.

Wave 2 covers other large companies – those exceeding at least two of three criteria: more than 250 employees, net turnover above EUR 50 million, or total assets above EUR 25 million. These entities report for the financial year 2025, with first publication in 2026. This is the wave that captures the widest range of Polish capital-group subsidiaries and domestically oriented corporations.

Wave 3 covers listed SMEs, small and non-complex credit institutions, and captive insurance undertakings. Their first reporting year is 2026 (publication in 2027), though listed SMEs may opt out until 2028. Wave 4, from 2028, will extend CSRD to non-EU parent companies with significant EU operations – relevant for Polish subsidiaries of third-country groups.

  • Wave 1 (FY 2024): large public-interest entities, over 500 employees
  • Wave 2 (FY 2025): large companies exceeding two of three size criteria
  • Wave 3 (FY 2026): listed SMEs, with opt-out available until 2028
  • Wave 4 (FY 2028): non-EU parent groups with material EU revenue

We advised a manufacturing client in the Mazowieckie region on Wave 2 threshold mapping in autumn 2025. The entity had restructured its workforce across two subsidiaries, bringing the headcount of each below 250. We identified that the combined turnover of the group still triggered the size threshold at consolidated level – a finding that changed the compliance timeline by a full year.

How does group structure affect the compliance obligation?

Group structure is where CSRD compliance becomes genuinely complex. A Polish subsidiary that does not independently meet the size thresholds may still fall within scope through its parent's consolidated reporting obligation – or may be exempt from preparing a separate sustainability statement if the parent's group report covers it.

Polish corporate legislation provides an exemption for subsidiaries whose parent prepares a consolidated sustainability statement covering the subsidiary, provided the subsidiary is included in that consolidated report and the report is prepared in accordance with CSRD or equivalent standards. The exemption requires the subsidiary to disclose, in its own management report, that it is relying on the group-level report and to identify the parent entity.

The exemption is not automatic. Three conditions must be met simultaneously: the parent's report must cover the subsidiary, the report must comply with ESRS or equivalent standards, and the subsidiary must make the required disclosure. Missing any one condition reinstates the individual reporting obligation. For a German investor's Polish subsidiary, this means verifying that the German parent's report – prepared under the German transposition of CSRD – meets Polish law's equivalence standard. This is a legal question, not an accounting one, and it requires early analysis.

Value chain reporting adds another layer. Even if a Polish entity is not directly in scope, its large customers or suppliers may require it to provide sustainability data under ESRS S1 (own workforce) or ESRS E1 (climate). Contractual pressure from value chain partners can effectively impose CSRD-equivalent obligations on out-of-scope entities. We recommend that Polish SMEs supplying to Wave 1 and Wave 2 companies begin data collection in 2025, at least 12 months before any formal obligation arises.

To discuss how your group structure affects the compliance timeline, reach out to info@kordeckipartners.com.

For foreign-owned Polish entities, the interaction between CSRD and existing compliance programme obligations is also worth examining. Our earlier analysis of compliance programme design for Cyprus subsidiaries in Poland addresses several structural issues that arise in a similar cross-border context.

What are the most common compliance mistakes in Poland?

Three structural errors account for the majority of CSRD compliance failures we encounter. Each carries an irreversible consequence if not corrected before the first reporting deadline.

The first error is treating CSRD as a reporting project rather than a data-governance project. Companies that start with the report template and work backwards quickly discover that the underlying data – emissions figures, supply-chain due diligence records, workforce metrics – simply does not exist in a form that meets ESRS requirements. Collecting 12 months of compliant data takes, in practice, 12 months. Starting late forfeits the ability to produce a first-year report without material gaps, which triggers assurance qualifications and potential regulatory scrutiny from KNF.

The second error is misapplying the double-materiality assessment. Polish companies frequently conduct a financial-materiality-only assessment, identify three or four topics, and consider the process complete. ESRS requires a structured stakeholder engagement process, documented methodology, and a written materiality statement. An underdocumented assessment is not merely a reporting deficiency – it undermines the legal defensibility of every disclosure that flows from it.

The third error concerns whistleblower compliance integration. CSRD requires companies to disclose their internal reporting channels and the mechanisms for protecting persons who report sustainability-related concerns. Polish law on whistleblower protection (ustawa o ochronie sygnalistów, the Whistleblower Protection Act) imposes parallel obligations. Companies that have not yet implemented compliant internal reporting channels will find that the CSRD disclosure requirement exposes that gap publicly. Our detailed analysis of whistleblower channel design and technical requirements sets out the minimum specification.

A mid-size IT company in Małopolska approached us in winter 2025 after its auditor flagged that the draft sustainability statement referenced an internal reporting channel that did not meet the Whistleblower Protection Act's technical requirements. Remediation required both legal and IT changes. The combined cost exceeded PLN 80,000 – avoidable with a six-month lead time.

What should Polish companies prepare – a practical checklist?

Preparation for CSRD compliance follows a logical sequence. Compressing the timeline increases cost and risk. The checklist below reflects the minimum viable preparation path for a Wave 2 entity with a December financial year-end.

  • Threshold assessment: confirm whether the entity meets two of three size criteria at standalone and consolidated level, and document the analysis
  • Double-materiality assessment: engage stakeholders, document methodology, produce a written materiality statement covering all twelve ESRS topic areas
  • Data gap analysis: map required ESRS data points against existing data sources; identify gaps and assign data owners
  • Governance and controls: update management report procedures, assign board-level responsibility for sustainability statement sign-off
  • Assurance readiness: engage a statutory auditor or independent assurance provider at least 6 months before the reporting deadline

Timeline costs vary significantly by company size and data maturity. A large Polish group with existing ESG reporting infrastructure may spend PLN 150,000 to PLN 400,000 on CSRD implementation. An entity starting from zero – no prior non-financial reporting, no emissions data, no supply-chain due diligence programme – should budget materially more and plan for an 18-month implementation window.

Board members should also be aware that CSRD sustainability statements form part of the management report, which directors sign. Personal liability for materially false or misleading statements in the management report exists under Polish corporate legislation. The interaction between CSRD disclosure obligations and director liability is analysed in our guide on D&O insurance coverage for Polish directors.

Specific preparation needs depend on your entity's structure and data maturity. To receive an expert assessment of your CSRD readiness, contact info@kordeckipartners.com.

Frequently asked questions

Q: If our Polish subsidiary is covered by our EU parent's group CSRD report, do we need to do anything at all?

A: The group-level exemption reduces but does not eliminate your obligations. Your subsidiary must still include a specific disclosure in its own management report stating that it relies on the parent's consolidated sustainability statement, identifying the parent, and confirming that the parent's report was prepared in accordance with CSRD or equivalent standards. Failing to include this disclosure reinstates the full individual reporting obligation. The assessment of whether the parent's report qualifies as equivalent requires legal review, not just an accountant's sign-off.

Q: How long does a proper double-materiality assessment take, and what does it cost?

A: For a mid-size Polish company with a straightforward value chain, a structured double-materiality assessment typically takes between 8 and 14 weeks from kick-off to final documented output. Costs depend heavily on whether you use an external adviser or conduct the process internally with external quality control. External-led assessments for a company with annual turnover around EUR 60 million typically range from PLN 40,000 to PLN 120,000. The most common misconception is that a materiality assessment is a one-time exercise – ESRS requires it to be reviewed and updated when circumstances change materially.

Q: Does CSRD apply to Polish branches of foreign companies?

A: A Polish branch (oddział) is not a separate legal entity and does not independently meet the definition of an undertaking subject to CSRD. The reporting obligation sits with the foreign parent. However, if the foreign parent is a non-EU entity that meets the Wave 4 threshold – more than EUR 150 million in net EU turnover for two consecutive years and at least one large EU subsidiary or listed EU subsidiary – the group will be required to produce a CSRD-equivalent group sustainability statement from financial year 2028. Polish branches of such groups should begin data-collection preparation well in advance of that deadline.

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 transition from NFRD to CSRD. To discuss your situation, contact info@kordeckipartners.com.

Anna Witkowska
Anna specialises in compliance, ESG, and internal investigations.

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.