The new ESG obligations in Poland: What changes await businesses in 2025? | News Flash

ESG (Environmental, Social, Governance) reporting is becoming increasingly important in light of the new reporting obligations introduced under the CSRD (Corporate Sustainability Reporting Directive). From 1 January 2025, Polish companies will be required to disclose detailed sustainability information and ESG reporting will become an essential part of doing business. Failure to report can result in both financial and reputational consequences.

Who is affected by the new ESG obligations in Poland?

The new ESG obligations in Poland cover large business units that meet at least two of the following criteria:

• annual average employment exceeding 250 employees
• annual turnover exceeding 40 million euros
• total assets exceeding 20 million euros.

The new ESG reporting obligation in Poland also applies to listed companies regardless of their size. From 2026, smaller listed companies will also be subject to ESG reporting, and from 2028, selected small and medium-sized companies.

Scope of the new ESG obligations in Poland

ESG reporting is based on the European Sustainability Reporting Standards (ESRS) and covers three main areas:

ESG deadlines and reporting procedures in Poland

The ESG report for the financial year 2025 must be submitted by the end of the first quarter of 2026. This document must be:

• Submitted to the National Court Register (KRS) as part of the company’s management report,
• Audited – the report must be verified by a certified auditor or an accredited certifying entity,
• Published on the company’s website to provide access for stakeholders.

Consequences of non-compliance with the new ESG obligations in Poland

Failure to comply with ESG reporting requirements may result in:

• Administrative and financial penalties,
• Difficulty obtaining funding from banks and investment funds,
• Loss of business partners requiring ESG compliance,
• Limited access to public procurement and EU programs.

Support from Accace Legal

Accace Legal offers comprehensive support in implementing and reporting ESG, including:

• Analysis of obligations under the CSRD and adapting business activities to the new regulations,
• Developing ESG strategies and internal policies in line with EU requirements,
• Preparing and verifying ESG reports, ensuring compliance with ESRS,
• Assistance with ESG audits and cooperation with certifying entities,
• Ongoing legal and tax advice in relation to ESG and regulatory obligations.

Due to the broad scope of new obligations and the potential risk of penalties, businesses should take immediate steps to comply with CSRD requirements. Accace Legal provides comprehensive legal services and advice in this area, minimizing the risk of improper ESG reporting.

If you are interested in support with the ESG reporting process, we encourage you to contact our team of experts.

Jakub Nasiłowski

Legal Manager | Accace Poland

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Dominik Szupernak

Associate | Accace Poland

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