Are the requirements of CSRD transposed? If yes, what was the implementation date and what is the name of the legislation?
Yes, in principle. 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 below. Poland transposed the CSRD through amendments to the Accounting Act of September 29, 1994 and the Act on Statutory Auditors, Audit Firms and Public Supervision of May 11, 2017, primarily via an amending act adopted on December 6, 2024. The transposition deadline was July 6, 2024, with supporting secondary legislation issued in 2025. The framework applies in line with the EU CSRD phased implementation timetable. The Stop-the-Clock Directive was transposed through a law of July 9, 2025.
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 legislation document cannot be translated due to the file exceeding the maximum allowed character limit. This should be double-checked with the relevant key contact.
Do any enforcement provisions, such as sanctions or penalties exist under local law for non-compliance with CSRD?
Yes.
If the CSRD has not yet been transposed, what steps have been taken towards implementation?
Transposition in process.
© Eversheds Sutherland. All rights reserved. Eversheds Sutherland is a global provider of legal and other services operating through various separate and distinct legal entities. Eversheds Sutherland is the name and brand under which the members of Eversheds Sutherland Limited (Eversheds Sutherland (International) LLP and Eversheds Sutherland (US) LLP) and their respective controlled, managed and affiliated firms and the members of Eversheds Sutherland (Europe) Limited (each an "Eversheds Sutherland Entity" and together the "Eversheds Sutherland Entities") provide legal or other services to clients around the world. Eversheds Sutherland Entities are constituted and regulated in accordance with relevant local regulatory and legal requirements and operate in accordance with their locally registered names. The use of the name Eversheds Sutherland, is for description purposes only and does not imply that the Eversheds Sutherland Entities are in a partnership or are part of a global LLP. The responsibility for the provision of services to the client is defined in the terms of engagement between the instructed firm and the client.
Connect with us
