ESRS implementation steps for Polish reporting

A Kraków-based manufacturer with 600 employees receives a letter from its German parent in March 2026. The parent needs a consolidated sustainability report under the Corporate Sustainability Reporting Directive (CSRD) by June. The Polish subsidiary has no ESG reporting structure, no data collection process, and no legal team familiar with European Sustainability Reporting Standards (ESRS). The clock is already running.

Polish entities subject to CSRD must prepare sustainability disclosures in line with ESRS, the mandatory reporting framework adopted by the European Commission. The first wave of large public-interest entities began reporting in 2025 for the financial year 2024. Subsequent waves extend obligations to large non-listed companies and, eventually, listed SMEs. Non-compliance exposes companies to reputational damage, regulatory sanctions, and loss of financing from ESG-sensitive lenders.

This guide walks through the ESRS implementation process step by step: identifying your reporting obligation, conducting a double materiality assessment, building data infrastructure, preparing the sustainability statement, and managing ongoing compliance. Three business scenarios – a manufacturer, an IT services company, and a foreign-owned subsidiary – illustrate how the framework applies in practice. A checklist and FAQ close the guide.

Who must comply, and when?

The starting point is always the same: determine whether your entity falls within CSRD scope. Under Polish corporate legislation implementing the Directive, the obligation applies in three waves. Large public-interest entities with over 500 employees reported first, covering financial year 2024. Large companies meeting two of three thresholds – net turnover above EUR 40 million, balance sheet above EUR 20 million, or over 250 employees – report from financial year 2025. Listed SMEs follow from 2026, with an opt-out available until 2028.

The Komisja Nadzoru Finansowego (Polish Financial Supervision Authority, KNF) supervises compliance for listed entities. The Krajowy Rejestr Sądowy (National Court Register, KRS) records the statutory filings that accompany annual reports. The Polska Agencja Rozwoju Przedsiębiorczości (Polish Agency for Enterprise Development, PARP) has published guidance for SMEs considering voluntary early adoption. Understanding which supervisory body monitors your entity shapes how you approach the implementation timeline.

Subsidiaries of foreign groups face a particular complication. A Polish subsidiary may not independently trigger CSRD thresholds but still needs to supply data to a parent that does. In that scenario, the subsidiary bears no standalone reporting obligation – but contractual obligations imposed by the parent effectively create the same data burden. We secured a compliance programme build-out for a German investor's Polish subsidiary in Mazowieckie (autumn 2025), enabling the parent to consolidate ESRS disclosures on schedule.

What to check at this stage:

Headcount, turnover, and balance sheet for the last two financial years
Whether the entity is listed on a regulated market in Poland or the EU
Whether a foreign parent has already imposed contractual ESG data requirements
The applicable reporting year and filing deadline under Polish transposition rules

How does the double materiality assessment work?

Double materiality is the analytical core of ESRS. It asks two questions simultaneously: does a sustainability topic affect the company financially (financial materiality), and does the company affect people or the environment through that topic (impact materiality)? Both dimensions must be assessed before any disclosure is written. ESRS requires entities to document the process, not just the outcome.

The assessment begins with a long list of potential topics drawn from the twelve sector-agnostic ESRS standards. These cover climate, pollution, water, biodiversity, circular economy, workforce, value chain workers, affected communities, consumers, and business conduct. Each topic is scored against likelihood, severity, and scale of impact on one axis, and against financial effect on the other. Topics that pass the materiality threshold on either axis must be reported in full.

For a Polish manufacturing company, climate-related topics typically clear the materiality bar quickly. Scope 1 and Scope 2 emissions are measurable and material. Supply chain labour practices in the value chain are harder to assess but often material for companies sourcing from outside the EU. An IT services company, by contrast, may find that Scope 3 emissions from data centres and employee governance topics dominate its materiality map.

The process usually takes between six and twelve weeks for a mid-sized entity. It requires input from finance, operations, HR, procurement, and legal. External facilitation accelerates the process and reduces the risk of gaps that auditors will later flag. Errors at this stage are expensive: a missed material topic means a deficient sustainability statement and potential regulatory scrutiny from the KNF or the statutory auditor responsible for limited assurance.

What data infrastructure does ESRS require?

Once material topics are confirmed, the entity must collect, verify, and store the underlying data. ESRS disclosure requirements are granular. Climate standards alone demand Scope 1, 2, and 3 greenhouse gas figures, transition plan details, physical risk assessments, and climate governance information. Social standards require workforce headcount by gender and contract type, pay gap data, and health and safety incident rates. Each data point needs a defined source, a collection method, and an audit trail.

Most Polish companies discover at this stage that their existing ERP and HR systems were not built for ESG reporting. Data sits in spreadsheets, is inconsistently defined across business units, or is simply not collected. Closing these gaps takes time. Budget at least three to four months for a data gap analysis, system configuration, and a test collection cycle before the first report is due.

For a foreign-owned subsidiary, the data infrastructure question intersects with group-level systems. The parent may impose a specific ESG reporting platform – SAP Sustainability Footprint Management, for example, or a dedicated SaaS tool. The Polish entity must integrate its local data feeds into that platform. This often requires IT project management that sits outside the legal team's scope but must be coordinated with it. Our team supported a Pomerania-based logistics company in mapping its data flows to a group ESRS template, reducing consolidation time by approximately eight weeks (spring 2026).

Whistleblower compliance also connects here. ESRS requires disclosure of internal reporting channels for sustainability concerns. If your entity has not yet implemented a whistleblower system under the EU Whistleblowing Directive – transposed into Polish law by the Act on the Protection of Whistleblowers – the ESRS implementation project is the natural moment to do so. Failure to maintain a functioning channel is itself a reportable governance gap. For a broader view of compliance programme design, see our guide on compliance programme design for UAE subsidiaries in Poland.

How is the sustainability statement drafted and assured?

The sustainability statement is a standalone section of the management report. Under Polish corporate legislation implementing CSRD, it must follow the structure and disclosure requirements of the applicable ESRS standards. The statement covers governance, strategy, impact and risk management, and metrics and targets – the four pillars that run through every ESRS standard. Each material topic requires disclosures under all four pillars.

Drafting typically takes eight to twelve weeks for a first-year report. The legal team's role is to ensure that disclosures are accurate, consistent with other parts of the annual report, and compliant with the specific language requirements of ESRS. Finance and sustainability teams own the underlying data. Communications teams may seek to soften or embellish language – a practice that creates greenwashing risk and must be resisted. The KNF has signalled that it will scrutinise listed entities' sustainability statements for misleading claims.

Limited assurance by a statutory auditor or an accredited third-party assurance provider is mandatory from the outset. The assurance engagement covers whether the sustainability statement was prepared in accordance with ESRS and whether the reporting process met the required standards. Assurance fees for a mid-sized Polish company typically range from PLN 80,000 to PLN 250,000 depending on the complexity of the materiality assessment and the number of material topics. Budget for this early – assurance providers are already heavily booked for 2026 reporting cycles.

Tax implications of ESG investments should also be considered during this phase. R&D relief, IP Box, and green investment incentives may be available for sustainability-related expenditure. For a detailed view of the available instruments, see our tax practice page for Poland. AML obligations intersect with ESRS governance disclosures: entities subject to the Ustawa o przeciwdziałaniu praniu pieniędzy (Anti-Money Laundering Act) must ensure that their business conduct disclosures accurately reflect their AML framework.

What are the most common implementation mistakes?

Starting too late is the single most damaging mistake. ESRS requires retrospective data for comparative periods. A company that begins implementation six months before its filing deadline will not have twelve months of verified data. The sustainability statement will be deficient, the auditor will issue a qualified assurance opinion, and the company forfeits the credibility benefit that early, clean reporting delivers to lenders and investors.

The second common mistake is treating ESRS as a reporting exercise rather than a governance project. Sustainability reporting is not a disclosure form. It requires board-level oversight, defined accountability for each material topic, and integration of sustainability risks into the company's risk management framework. Entities that assign ESRS implementation solely to the legal or finance department – without board engagement – produce statements that lack strategic coherence and fail to satisfy the governance disclosures in ESRS 2.

A third mistake is underestimating value chain obligations. ESRS requires companies to report on material impacts, risks, and opportunities across the full value chain – not just within the company's direct operations. For a Polish manufacturer sourcing raw materials from outside the EU, this means collecting supplier data, conducting due diligence, and potentially redesigning procurement contracts. Companies that ignore value chain disclosures face gaps that auditors will identify and that downstream customers – particularly large German or French buyers – will notice.

For Swiss-owned subsidiaries operating in Poland, implementation complexity increases further. Cross-border governance structures, dual reporting obligations, and differing group and local timelines all create friction. Our guide on compliance programme design for Switzerland subsidiaries in Poland addresses these multi-jurisdictional dynamics in detail.

A practical checklist for avoiding these mistakes:

Begin the double materiality assessment at least 14 months before the filing deadline
Assign board-level sponsorship and a dedicated cross-functional project team
Engage an assurance provider at least 10 months before filing
Map value chain data requirements and update supplier contracts accordingly
Integrate whistleblower and AML governance disclosures into the project scope

ESG reporting obligations do not pause for companies in the middle of corporate restructuring. If your entity is undergoing a merger, spin-off, or change of control, the ESRS implementation timeline must be coordinated with transaction counsel. Personal liability of directors for materially false sustainability statements is a live risk under Polish corporate legislation – and one that is not yet well understood in the market.

Specific situations carry irreversible consequences. A sustainability statement filed with material omissions cannot simply be corrected after the fact. The KNF has the authority to impose administrative sanctions on listed entities for non-compliant disclosures. For large non-listed companies, reputational damage with banks and investors can close financing windows that do not reopen. The cost of getting this right the first time is a fraction of the cost of remediation.

To receive an expert assessment of your entity's ESRS readiness and reporting timeline, contact info@kordeckipartners.com.

Frequently asked questions

Q: Can a Polish subsidiary rely entirely on its foreign parent's group sustainability statement?

A: In some cases, yes. Where the Polish subsidiary is consolidated into a group report that meets ESRS requirements, Polish corporate legislation allows an exemption from a standalone subsidiary statement. However, the exemption has conditions: the parent's report must be publicly available, the subsidiary must disclose the parent entity's identity and registered office, and the KRS filing must reference the group report. The exemption does not eliminate the need to supply data to the parent – it only removes the obligation to publish a separate statement.

Q: How long does a full ESRS implementation project take, and what does it cost?

A: For a mid-sized Polish company reporting for the first time, a realistic timeline is 12 to 18 months from project launch to a filed, assured sustainability statement. Costs vary significantly. Internal project management, external legal and sustainability advisory, IT system changes, and assurance fees together typically amount to PLN 300,000 to PLN 700,000 for a company with 300 to 800 employees. Companies that have already invested in ISO 14001 or ISO 45001 certification, or that have a functioning compliance programme, start from a stronger base and can reduce advisory costs materially.

Q: Is ESRS the same as the GRI or TCFD frameworks my company already uses?

A: No, though there is significant conceptual overlap. ESRS is a mandatory EU legal standard. GRI (Global Reporting Initiative) and TCFD (Task Force on Climate-related Financial Disclosures) are voluntary frameworks. ESRS was designed with interoperability in mind: companies that already report under GRI will find that many data points transfer. TCFD's four-pillar structure maps onto ESRS 2's governance, strategy, risk management, and metrics pillars. However, ESRS imposes specific disclosure requirements, a defined assurance process, and a structured digital tagging format (iXBRL) that GRI and TCFD do not require. Existing voluntary reporting reduces effort but does not substitute for ESRS compliance.

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 governance. We work with Polish entrepreneurs, foreign investors, and in-house legal teams navigating their first ESRS reporting cycle. To discuss your situation, contact info@kordeckipartners.com.