On paper, the transition to European Sustainability Reporting Standards (ESRS) looks like a documentation exercise. In practice, it reshapes how Polish companies gather data, govern disclosures, and manage third-party relationships – with binding deadlines already in force for the largest entities and a rolling timetable extending to smaller firms.

ESRS implementation in Poland is driven by the Corporate Sustainability Reporting Directive (CSRD), transposed into Polish law through amendments to the Accounting Act. Entities meeting the "large undertaking" threshold – more than 250 employees, EUR 40m in net turnover, or EUR 20m in total assets (two of three criteria) – must report under ESRS for financial years beginning on or after 1 January 2024. Failure to comply exposes the company and its board to regulatory sanctions, audit qualification, and reputational damage that cannot be undone retroactively.

This alert covers the three areas that demand immediate attention: the scope of affected entities, the concrete steps required before the first reporting deadline, and the governance changes that must be embedded now. Each section includes at least one specific figure or deadline so your team can calibrate urgency without further research.

Who is affected by CSRD Poland requirements and when?

The CSRD introduces a phased scope. The first wave – already active – covers entities previously subject to the Non-Financial Reporting Directive (NFRD): listed companies, banks, and insurers with more than 500 employees. These entities report on financial year 2024, meaning the first ESRS-compliant sustainability statement is due alongside the 2024 annual report, typically by 30 June 2025. Missing this window is not a technical deficiency; it triggers audit qualification and potential liability of board members for incomplete statutory filings.

The second wave brings in all other large undertakings meeting the two-of-three threshold above. They report for financial year 2025, with statements due in 2026. A third wave, covering listed small and medium-sized enterprises (SMEs), applies from financial year 2026 onward, though SMEs may opt out until 2028. Polish subsidiaries of non-EU parent groups with EU turnover exceeding EUR 150m face additional obligations under the value-chain reporting rules embedded in ESRS 2 – the general disclosure standard that applies to every in-scope entity without exception.

Two practical checkpoints follow from this timetable. First, confirm your entity's classification in the National Court Register (Krajowy Rejestr Sądowy, KRS) against the updated thresholds – the 2023 amendments raised the balance-sheet limit, and some companies that were previously in scope have moved out. Second, map your group structure: a Polish operating company may be out of scope individually but still required to supply sustainability data to a parent that is in scope. The Polish Financial Supervision Authority (Komisja Nadzoru Finansowego, KNF) has signalled that it will scrutinise group-level disclosure gaps for listed entities.

What are the immediate ESRS implementation steps?

The first concrete action is a double materiality assessment. ESRS requires companies to evaluate both financial materiality (how sustainability factors affect the business) and impact materiality (how the business affects people and the environment). This assessment must be documented, auditable, and completed before the sustainability statement is drafted. Allocate at least eight weeks for a first-cycle assessment in a mid-size organisation.

We assisted a manufacturing client in the Mazowieckie region to complete its double materiality assessment and gap analysis against ESRS E1 (climate change) and S1 (own workforce) in autumn 2024. The process identified 14 data gaps that required new internal reporting lines – none of which had been flagged in the company's prior voluntary ESG reporting.

The second action is data architecture. ESRS demands quantitative disclosures across environmental, social, and governance topics. Many Polish companies collect this data across disconnected systems – HR platforms, energy invoices, supplier questionnaires. A central data register, with clear ownership and audit trail, must be in place before the reporting period closes. Retrofitting data after year-end is possible but expensive and legally risky if it creates inconsistencies with other statutory filings.

  • Assign a named ESRS data owner at board or senior management level
  • Complete double materiality assessment at least eight weeks before year-end
  • Map data sources against each applicable ESRS topic standard
  • Engage your statutory auditor on limited assurance scope no later than Q3 of the reporting year
  • Review whistleblower compliance channels – ESRS S1 and S2 reference internal reporting mechanisms

The third action is assurance readiness. CSRD mandates limited assurance of the sustainability statement from the first reporting year, moving to reasonable assurance in due course. Polish auditors registered with the Polish Agency for Audit Oversight (Polska Agencja Nadzoru Audytowego, PANA) are the only entities authorised to provide this assurance. Engaging your auditor early – ideally six months before year-end – avoids the capacity constraints that are already visible in the Warsaw market.

For companies with cross-border supply chains, ESRS G1 (business conduct) intersects directly with AML compliance obligations for Polish companies. Due diligence on suppliers and counterparties feeds both frameworks, so integrating the two workstreams reduces duplication and strengthens both programmes. Similarly, the governance disclosures required under ESRS 2 overlap with the internal control frameworks discussed in our alert on compliance programme design for Ukraine subsidiaries in Poland.

Board members should also note the personal dimension. Sustainability statements form part of the management report, which directors sign. Inaccurate or incomplete ESRS disclosures expose signatories to the same liability regime that applies to false financial statements. Our analysis of fiscal criminal defence and KKS strategy for board members sets out how personal liability can crystallise from statutory reporting failures – the mechanism is analogous here.

Specific situation at your company requires an assessment before the reporting window closes. Gaps identified after year-end are far harder to remedy and may preclude a clean assurance opinion – an irreversible outcome for the first reporting cycle.

If your entity meets the large-undertaking threshold or supplies data to an in-scope group parent, contact info@kordeckipartners.com. We will map your ESRS obligations, identify material data gaps, and coordinate with your auditor on assurance scope.

Frequently asked questions

Q: Does ESRS apply to Polish companies that are not listed on a stock exchange?

A: Yes. The CSRD scope extends to all large undertakings meeting two of three criteria – employee count, turnover, and balance-sheet total – regardless of listing status. Unlisted Polish limited liability companies (spółki z ograniczoną odpowiedzialnością) and joint-stock companies (spółki akcyjne) that exceed the thresholds are fully in scope. Only SMEs below the thresholds are currently exempt, with a separate voluntary standard available to them from 2026.

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

A: For a mid-size Polish company with a single reporting entity and limited value-chain complexity, a first-cycle assessment typically requires six to ten weeks and involves workshops with finance, operations, HR, and procurement teams. External advisory fees vary widely; budget a minimum of PLN 40,000 for a structured process with documented outputs that will withstand auditor scrutiny. Rushing the assessment to save cost is the single most common mistake in first-year ESRS implementation.

Q: Is it a misconception that ESRS only covers environmental topics?

A: It is a widespread misconception. ESRS covers five environmental topics (E1–E5), four social topics (S1–S4), and one governance topic (G1), plus the cross-cutting general disclosures in ESRS 2. Social standards – including own workforce conditions, affected communities, and consumers – are mandatory where material. Governance disclosures on anti-corruption, lobbying, and supplier relationships are required for every in-scope entity, regardless of industry sector.

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. 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.