{"id":4565,"date":"2026-11-06T11:29:49","date_gmt":"2026-11-06T11:29:49","guid":{"rendered":"https:\/\/sawaryn.com\/?p=4565"},"modified":"2026-11-06T11:37:45","modified_gmt":"2026-11-06T11:37:45","slug":"esg-data-without-reporting-obligation-poland","status":"publish","type":"post","link":"https:\/\/sawaryn.com\/en\/publikacje\/esg-data-without-reporting-obligation-poland\/","title":{"rendered":"ESG without a reporting obligation. Why the market will still ask you for data – and what to prepare now"},"content":{"rendered":"

You will find out that ESG affects you not from the Journal of Laws, but from an email from your largest client: \u201cPlease complete the ESG questionnaire by Friday; this is a condition for renewing the contract”. And then it will turn out that the data is spread across four departments, the policies are buried in emails, and no one knows who is authorised to sign it.<\/p>\n

The question \u201cdo we have to report on ESG?” is the wrong one to ask. Even if your company is not subject to the sustainability reporting obligation under the CSRD, a major business partner, bank, investor or corporate group will still request ESG data from you \u2014 for its own reporting, a tender or due diligence. And being unprepared means delayed responses, lost contracts, a lower valuation and chaos within the organisation.<\/p>\n

In this article, I explain who is formally subject to the ESG reporting obligation<\/strong><\/a> in Poland, why companies outside its scope still need to prepare, what risks are associated with a lack of ESG data \u2014 and what to do step by step to avoid the trap of doing either too little or overinvesting in a reporting project your company does not need.<\/p>\n

Key terms before you continue<\/h2>\n

Before we go into detail \u2014 here are a few terms that will appear throughout the article. I will explain them once so that you do not have to stop along the way.<\/p>\n\n\n\n\n\n\n\n\n\n\n
Term<\/th>\nMeaning<\/th>\n<\/tr>\n<\/thead>\n
CSRD<\/strong><\/td>\nThe EU Corporate Sustainability Reporting Directive. In Poland, it was implemented by the Act of 6 December 2024<\/a> amending the Accounting Act. It imposes ESG reporting obligations on specific groups of companies.<\/td>\n<\/tr>\n
ESRS<\/strong><\/td>\nEuropean Sustainability Reporting Standards \u2014 they specify what data a company must disclose in its ESG report and in what format.<\/td>\n<\/tr>\n
Omnibus I<\/strong><\/td>\nDirective (EU) 2026\/470<\/a>, which narrowed the scope of the CSRD and postponed deadlines for some companies. Poland must implement it by 19 March 2027.<\/td>\n<\/tr>\n
CSDDD<\/strong><\/td>\nDirective (EU) 2024\/1760<\/a> on due diligence in the value chain \u2014 concerning human rights and the environment. Application date following the amendments: 26 July 2029.<\/td>\n<\/tr>\n
VSME<\/strong><\/td>\nA voluntary ESG reporting standard for small and medium-sized companies \u2014 European Commission Recommendation 2025\/1710<\/a>. It is not mandatory, but serves as a reference point for business partner questionnaires.<\/td>\n<\/tr>\n
Assurance (limited assurance)<\/strong><\/td>\nVerification of an ESG report by a statutory auditor \u2014 it provides limited assurance as to the accuracy of the data. It is not equivalent to a full audit of financial statements.<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

Who is formally required to report on ESG in Poland<\/h2>\n

The sustainability reporting obligation does not apply to every company. To determine whether your company is directly subject to it, check two things: the size thresholds and its status on a regulated market.<\/p>\n

\u201cLarge undertaking” thresholds under Polish law<\/h3>\n

The Polish act implementing the CSRD uses a 2-out-of-3 criteria test<\/strong>. If your company exceeds at least two of the following thresholds, it may be subject to the reporting obligation:<\/p>\n\n\n\n\n\n\n\n
Criterion<\/th>\nThreshold<\/th>\n<\/tr>\n<\/thead>\n
Total assets<\/td>\n25 million z\u0142<\/td>\n<\/tr>\n
Net revenue<\/td>\n50 million z\u0142<\/td>\n<\/tr>\n
Average annual number of employees<\/td>\n250 people<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

The obligation applies in three waves: first to entities that were already required to report non-financial information, then to other large entities and groups, and finally to SMEs listed on a regulated market (Source: Ministry of Finance<\/a>).<\/p>\n

Changes introduced by Omnibus I<\/h3>\n

The Omnibus I Directive<\/a> narrowed the scope of the CSRD at EU level to entities employing more than 1000 employees<\/strong> and generating more than EUR 450 million<\/strong> in annual net revenue. Poland must implement these changes by 19 March 2027<\/strong> \u2014 until then, the existing national thresholds remain in force.<\/p>\n

What does this mean? If your company falls between the Polish thresholds and the new EU thresholds, its status is uncertain. The obligation may change once Omnibus I is implemented. But that is no reason to wait.<\/p>\n

If you do not meet the thresholds \u2014 can you simply do nothing?<\/h3>\n

Formally, you are not subject to the reporting obligation. But that does not mean ESG does not affect you. Today, the real enforcer of these requirements is not a supervisory authority \u2014 it is your largest client, bank or investor.<\/p>\n

Why the market requires ESG data from companies not subject to reporting obligations<\/h2>\n

Pressure to provide ESG data does not arise solely from legislation. It stems from the fact that companies subject to reporting obligations must disclose information about their value chain<\/strong> \u2014 which includes you if you are their supplier, subcontractor or business partner.<\/p>\n

Four situations in which a lack of ESG data harms your business<\/h3>\n\n\n\n\n\n\n\n\n
Situation<\/th>\nWhat happens<\/th>\nConsequence<\/th>\n<\/tr>\n<\/thead>\n
ESG questionnaire from a business partner<\/strong><\/td>\nA major client sends an ESG questionnaire as a condition for renewing the contract. The data must be collected from HR, procurement, compliance and management within a few days.<\/td>\nNo response or an inconsistent response = risk of losing the contract.<\/td>\n<\/tr>\n
Tender with environmental requirements<\/strong><\/td>\nThe contracting authority requires environmental, social or supply-chain policies. The company does not have the necessary documents ready.<\/td>\nExclusion from the procedure or a weaker bidding position.<\/td>\n<\/tr>\n
Investor due diligence<\/strong><\/td>\nAn investor or fund asks about governance, employment policies, supplier relationships and environmental risks. The documentation is inconsistent or incomplete.<\/td>\nA prolonged process, a lower valuation and the use of ESG gaps as leverage in negotiations.<\/td>\n<\/tr>\n
Reporting to a corporate group<\/strong><\/td>\nThe parent company needs ESG data from its subsidiaries for a consolidated report.<\/td>\nChaotic data flows, no process owner and delays in group reporting.<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

Where do these requirements come from?<\/h3>\n
    \n
  1. CSRD and ESRS<\/strong> \u2014 companies subject to reporting obligations must disclose data about their value chain, including suppliers and subcontractors.<\/li>\n
  2. CSDDD<\/strong> \u2014 large companies are building due diligence systems and requesting data from suppliers as part of their own procedures, even though the directive\u2019s application date has been postponed to 26 July 2029 (Source: EUR-Lex<\/a>).<\/li>\n
  3. Banks and financial institutions<\/strong> \u2014 they request ESG data for their own disclosures under the CSRD, the Taxonomy Regulation and the SFDR. This includes Scope 1\u20133 emissions, transition plans, taxonomy-related data, workforce metrics and supply-chain data (Source: Statistics Poland\u2019s Statistical Review<\/a>).<\/li>\n
  4. Market tools<\/strong> \u2014 platforms such as EcoVadis and CDP have become the standard for supplier assessments in many industries. They are not legislation, but their scores influence business partners\u2019 purchasing decisions.<\/li>\n<\/ol>\n

    There is no single statutory ESG questionnaire \u2014 its scope depends on the purpose: credit, sustainability-linked financing, supplier assessment or portfolio reporting. Your company must therefore be prepared for different types of requests.<\/p>\n

    Contact us<\/a> \u2014 we will help you determine which ESG requirements apply to your company and what to prepare first.<\/p>\n