A Warsaw-based retail group with 280 employees and annual revenues just below EUR 40 million receives a request from its German parent: submit a sustainability report under the Corporate Sustainability Reporting Directive (CSRD) for the financial year ending December 2025. The Polish subsidiary's management board has no idea whether it is directly obligated, whether the parent's group report covers it, or what happens if nothing is filed. The answer determines whether the company faces regulatory penalties, loses access to bank financing, or forfeits contracts with ESG-conscious counterparties.

CSRD was transposed into Polish law through an amendment to the ustawa o rachunkowości (Accounting Act) and related legislation, extending sustainability reporting obligations to a progressively broader set of entities. Large public-interest entities with over 500 employees were first in scope from the financial year 2024. Large companies meeting two of three size thresholds – over 250 employees, EUR 40 million net turnover, or EUR 20 million total assets – must report from financial year 2025. Listed SMEs, small and non-complex credit institutions, and captive insurers enter scope from 2026 or later. Non-compliance exposes the company's board to personal liability and precludes access to sustainability-linked financing.

This guide sets out the step-by-step procedure for determining CSRD scope, explains the reporting timeline and key cost drivers, identifies the three most common compliance mistakes, and addresses the practical questions that Polish subsidiaries of foreign groups encounter most often. Three business scenarios – a manufacturing firm, an IT services company, and a foreign investor's Polish subsidiary – illustrate how the rules apply in practice.

Who falls within CSRD scope in Poland?

Polish corporate law distinguishes reporting obligations by entity type and size. The National Court Register (KRS) classification of an entity as a large company, a public-interest entity, or a listed SME determines which wave of CSRD obligations applies. The Komisja Nadzoru Finansowego (Polish Financial Supervision Authority, KNF) oversees compliance for regulated financial entities, while the Krajowy Rejestr Sądowy (National Court Register, KRS) records the statutory filings that flow from sustainability reporting obligations.

The first wave – financial year 2024, reports due in 2025 – covers public-interest entities already subject to non-financial reporting under the Non-Financial Reporting Directive (NFRD) with more than 500 employees. In Poland this means primarily Warsaw Stock Exchange-listed companies, banks, and insurers of that size. The second wave – financial year 2025, reports due in 2026 – covers large companies meeting at least two of three criteria: more than 250 employees, net turnover exceeding EUR 40 million, or total assets exceeding EUR 20 million. A Polish subsidiary of a foreign group may qualify independently on these thresholds, even if the parent files a consolidated group report.

The third wave targets listed SMEs from financial year 2026, with an opt-out available until 2028. Non-listed SMEs remain outside mandatory scope unless they are in the value chain of a reporting entity, which creates indirect pressure. The Urząd Komisji Nadzoru Finansowego (Office of the Polish Financial Supervision Authority, UKNF) has signalled active supervision of financial sector entities from the first wave onward.

  • Wave 1 (FY 2024): public-interest entities, more than 500 employees
  • Wave 2 (FY 2025): large companies, two of three size criteria
  • Wave 3 (FY 2026): listed SMEs, with opt-out to 2028
  • Indirect scope: value-chain suppliers of Wave 1 and Wave 2 reporters

One common misconception is that a Polish subsidiary is automatically covered by a parent's consolidated CSRD report. The group consolidation exemption is available but conditional. The parent must itself be subject to CSRD or equivalent rules, the subsidiary must be included in the consolidated report, and the exemption must be formally invoked in the subsidiary's own financial statements. Failing to document this correctly means the Polish entity remains in breach – a risk that closes doors with lenders and public procurement bodies.

What does the reporting process actually require?

CSRD reporting is not a checkbox exercise. It requires a structured internal process, external assurance, and integration with the company's financial reporting cycle. The European Sustainability Reporting Standards (ESRS) define the disclosure framework. A Polish company in Wave 2 must complete a double materiality assessment, identify applicable ESRS topics, collect quantitative and qualitative data across the business, and obtain limited assurance from a registered auditor – all within the annual reporting cycle.

The double materiality assessment is the foundation. It asks two questions simultaneously: how do sustainability matters affect the company's financial performance (financial materiality), and how does the company's activity affect people and the environment (impact materiality)? Both perspectives are mandatory. Many Polish companies underestimate the time this takes. A manufacturing firm with 300 employees typically needs eight to twelve weeks to complete a credible double materiality process from scratch.

We supported a manufacturing client in the Mazowieckie region in completing its first CSRD double materiality assessment and ESRS data mapping (autumn 2025). The process identified 14 material topics, required coordination across four internal departments, and produced a gap analysis that became the basis for the company's sustainability report filed within the statutory deadline.

Data collection follows the materiality assessment. ESRS E1 on climate covers Scope 1, 2, and 3 greenhouse gas emissions. ESRS S1 covers the company's own workforce. ESRS G1 addresses governance and anti-corruption. Each standard specifies mandatory and voluntary disclosure points. Polish companies must also comply with the whistleblower protection framework under the ustawa o ochronie sygnalistów (Whistleblower Protection Act), which intersects with ESRS G1 governance disclosures. For a deeper look at how compliance programmes interact with CSRD governance requirements, see our guide on compliance programme design for France subsidiaries in Poland.

External limited assurance must be provided by a biegły rewident (statutory auditor) or audit firm registered with the Polska Agencja Nadzoru Audytowego (Polish Audit Oversight Agency, PANA). The assurance engagement adds cost – typically PLN 30,000 to PLN 120,000 for a mid-sized Polish company, depending on complexity and scope. Budget for this from the outset. Leaving the auditor appointment to the final quarter of the reporting year is one of the most common and expensive mistakes.

How do the three business scenarios differ in practice?

Scope and complexity vary significantly depending on the business model. Three scenarios illustrate the practical divergence: a manufacturing firm, an IT services company, and a foreign investor's Polish subsidiary entering scope through the group consolidation route.

Manufacturing firm, 320 employees, Silesia. This company meets two of three Wave 2 thresholds from financial year 2025. Its material ESRS topics include E1 (climate and emissions), E2 (pollution from production processes), S1 (workforce health and safety), and G1 (anti-corruption). Scope 3 emissions from the supply chain present the greatest data challenge. The company must engage its top 20 suppliers to collect emissions data – a process that takes at least three months and requires contractual data-sharing clauses. Total first-year compliance cost: PLN 180,000 to PLN 250,000, including internal resource, consultancy, and assurance fees.

IT services company, 260 employees, Warsaw. This firm meets the employee threshold and likely the turnover threshold. Its material ESRS topics are narrower: primarily S1 (workforce diversity and wellbeing), G1 (governance and ethics), and potentially E1 if the company has significant data centre energy consumption. The double materiality assessment may conclude that environmental topics other than energy are not material. This reduces disclosure scope and cost. Estimated first-year cost: PLN 80,000 to PLN 130,000. The company should also review its AML compliance obligations, which interact with ESRS G1 governance disclosures – see our analysis of AML compliance obligations for Polish companies.

Foreign investor's Polish subsidiary, 180 employees, Małopolska. This entity does not meet Wave 2 thresholds independently. However, its German parent is a Wave 1 reporter and requests sustainability data under ESRS value-chain disclosure obligations. The subsidiary is not legally required to file its own CSRD report but must provide data to the parent within agreed timelines. If the parent's group report covers the subsidiary, management must formally document the consolidation exemption in the Polish entity's financial statements. Failure to do so exposes the subsidiary's board to personal liability for incorrect financial statement disclosures – a risk explored further in our article on board liability under Polish corporate law.

We obtained a formal legal opinion protecting a foreign investor's subsidiary in Lower Silesia from premature CSRD scope attribution by its parent's compliance team (spring 2026). The opinion clarified the consolidation exemption conditions and saved the client an estimated EUR 60,000 in unnecessary first-year reporting costs.

What are the most common CSRD compliance mistakes in Poland?

Polish companies entering CSRD scope for the first time make predictable errors. Identifying them early avoids the irreversible consequence of a late or deficient report – which triggers supervisory scrutiny, damages lender relationships, and forfeits eligibility for sustainability-linked credit facilities.

The first mistake is misidentifying the reporting entity. A Polish holding company may believe it is exempt because its operating subsidiaries are below the size thresholds individually. But if the holding company itself meets two of three criteria on a consolidated basis, it is directly in scope. Polish corporate law requires the assessment at the level of the entity obligated to prepare financial statements – not at group level alone.

The second mistake is treating CSRD as a finance department task. ESG reporting requires input from HR (workforce data), operations (environmental metrics), procurement (supply chain emissions), and legal (governance and anti-corruption disclosures). Without a cross-functional project team established at least 12 months before the report deadline, data gaps are inevitable. A 12-month lead time is the minimum for Wave 2 first-time reporters.

The third mistake is ignoring the whistleblower compliance dimension. ESRS G1 requires disclosure of the company's governance structures for reporting misconduct. Polish companies must have an internal reporting channel under the Whistleblower Protection Act in place before they can make credible G1 disclosures. Companies that lack this channel face a dual exposure: non-compliance with the Whistleblower Act (fines up to PLN 60,000) and incomplete CSRD governance disclosures.

  • Verify the reporting entity perimeter before assuming group exemption applies
  • Establish a cross-functional CSRD project team at least 12 months ahead
  • Appoint a statutory auditor for limited assurance by Q2 of the reporting year
  • Implement the internal whistleblower channel before preparing G1 disclosures
  • Document the consolidation exemption formally in the subsidiary's financial statements

A fourth error – less common but more costly – is filing a report that claims a consolidation exemption without meeting all conditions. If the parent company's report is published after the Polish subsidiary's statutory filing deadline, the exemption fails. The Polish entity is then in breach for the full reporting year, with no retroactive cure available. This precludes access to ESG-linked bank products for the following 12 months at minimum.

Frequently asked questions

Q: Does a Polish subsidiary of an EU parent automatically avoid CSRD filing if the parent reports under CSRD?

A: Not automatically. The consolidation exemption requires three conditions to be met simultaneously: the parent must be subject to CSRD or equivalent rules, the Polish subsidiary must be included in the parent's consolidated sustainability report, and the exemption must be formally stated in the Polish subsidiary's own financial statements. If any condition is absent, the subsidiary remains individually obligated. The exemption must be actively claimed and documented – it does not apply by default.

Q: What does limited assurance under CSRD actually cost in Poland, and when should we budget for it?

A: Limited assurance fees for a mid-sized Polish company typically range from PLN 30,000 to PLN 120,000, depending on the number of material ESRS topics, the quality of the company's internal data systems, and the audit firm's scope. Budget for this cost in the same financial year as the reporting obligation arises. Auditors with CSRD capacity are in short supply in Poland. Companies that approach audit firms in Q4 of the reporting year face higher fees and risk missing the statutory deadline for the auditor's report.

Q: Is a Polish company with 240 employees currently outside CSRD scope entirely?

A: A company with 240 employees is below the Wave 2 employee threshold of 250 and may fall outside mandatory scope – but only if it also does not meet two of the three size criteria on a combined basis. More importantly, if that company is a supplier to a Wave 1 or Wave 2 reporter, it will receive data requests under the value-chain disclosure obligations of ESRS standards. While those requests carry no direct legal sanction, failure to respond risks losing the supply relationship. Many Polish SMEs are investing in basic ESG data infrastructure now precisely to protect commercial relationships.

The specific situation of each company requires individual assessment. Threshold calculations, consolidation exemption conditions, and ESRS materiality scoping all depend on facts that vary by entity. An incorrect scope determination forfeits access to sustainability-linked financing and exposes the board to personal liability for incorrect financial statement disclosures.

To receive an expert assessment of your company's CSRD reporting obligations, contact info@kordeckipartners.com. Our team will review your entity structure, size thresholds, and group consolidation position, advise on the double materiality process and ESRS data requirements, and coordinate the statutory auditor appointment for limited assurance.

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 reporting, and sustainability governance. We work with Polish entrepreneurs, foreign investors, and in-house legal teams navigating mandatory sustainability disclosure 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.