Are the requirements of CSRD transposed? If yes, what was the implementation date and what is the name of the legislation?
Yes. The CSRD has been transposed into national law through the Act of 6 December 2024 amending the Accounting Act, the Act on Statutory Auditors, Audit Firms and Public Oversight, and certain other acts (Dz.U. 2024 poz. 1863). The legislation entered into force principally on 1 January 2025 and implements Directive (EU) 2022/2464. The European Commission records Poland as having fully transposed the original CSRD.
The transposing legislation implements the core CSRD obligations, including reporting on environmental, social and governance factors, subject to the scope, assurance and enforcement provisions described in the adjacent columns.
The Stop-the-Clock Directive was transposed through a law of 09 July 2025.
The Omnibus I Directive has been partially transposed throw the Accounting Acton 13 March 2026. Poland's full transposition deadline is 19 March 2027.
Has the local legislation extended the scope of the CSRD, by adding any additional requirements or going beyond the Directive in any way?
Yes (limited/technical).
Poland is generally assessed as introducing limited gold-plating, mainly of a procedural and formal nature rather than substantive expansion of CSRD requirements.
How does the transposition affect different types of companies? Are there specific provisions for different sizes or types of companies, such as SMEs versus large enterprises?
The original CSRD framework applies differently depending on company size and type. Large undertakings and parent companies of large groups are subject to sustainability reporting requirements, while listed SMEs were also brought within the original CSRD scope, subject to specific transitional arrangements.
The Omnibus I amendments substantially narrow this scope. Under the new EU framework, CSRD reporting is generally limited to undertakings and groups with more than 1,000 employees and net annual turnover exceeding EUR 450 million.
SMEs that fall outside these thresholds are therefore generally excluded from the mandatory CSRD reporting requirements.
Do any enforcement provisions, such as sanctions or penalties exist under local law for non-compliance with CSRD?
Yes. The amended Accounting Act provides for administrative penalties and fines for failure to comply with sustainability reporting obligations.
If the CSRD has not yet been transposed, what steps have been taken towards implementation?
Transposition in process.
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