Mandatory sustainability & GHG reporting requirements in Poland

Poland implements EU sustainability law rather than running a separate national ESG framework, so the obligations facing a company in Warsaw, Kraków, Wrocław or Poznań follow the EU rulebook — layered on top of Poland's pre-existing national emissions reporting. Here is how the pieces fit together in 2026.

CSRD is now Polish law

Poland transposed the CSRD through an amendment to the Act on Accounting (together with the Act on Statutory Auditors, Audit Firms and Public Oversight). The amending law was signed in December 2024 and entered into force at the end of that year. In-scope companies must prepare a sustainability statement as part of their management report, following the European Sustainability Reporting Standards (ESRS), based on a double-materiality assessment, tagged in a machine-readable (XHTML) format.

Who must report, and when

The CSRD phases in by company size and listing status. Because Poland has enacted the EU "stop-the-clock" directive (the amending law was adopted in July 2025), the second and third waves were each postponed by two years. In broad terms:

Size thresholds for a "large undertaking"

Under the rules as originally transposed, a company is a "large undertaking" — and therefore in scope for the broad CSRD wave — if it exceeds at least two of three criteria on consecutive balance-sheet dates: a balance-sheet total of around EUR 25 million (roughly PLN 110 million), net turnover of around EUR 50 million (roughly PLN 220 million), and an average of 250 employees. The first (NFRD legacy) wave additionally captured large public-interest entities with more than 500 employees. The 2026 Omnibus I package, however, sharply raises these thresholds for the future (see below), so the set of companies ultimately captured will be much smaller than the original transposition implied.

Omnibus I: a narrower long-term scope

The EU Omnibus I simplification directive was finalised and published in the Official Journal in February 2026 and entered into force shortly afterwards. It narrows the headline CSRD scope to companies with more than 1,000 employees and net turnover above EUR 450 million, applicable for financial years beginning on or after 1 January 2027 — a substantial reduction from the previous 250-employee bar. Poland has begun transposing Omnibus I in stages (an initial stage took effect in March 2026 introducing temporary exemptions for smaller wave-1 companies), with the remaining provisions still in the legislative pipeline. The practical effect: many mid-sized Polish companies that expected to fall under CSRD may no longer be directly obliged — but the data demands have not gone away (see VSME below).

Scope 3 and assurance

For in-scope companies, the climate standard ESRS E1 requires disclosure of gross Scope 1, Scope 2 and material Scope 3 greenhouse-gas emissions. For most Polish companies Scope 3 — especially purchased goods and services and upstream transport — dominates the footprint, so it is rarely immaterial. CSRD reports require limited assurance by a statutory auditor from the first reporting year (with a possible move to reasonable assurance later), which means every figure must be traceable to its source, unit, emission factor and data-quality level.

The SME and VSME picture

Most Polish SMEs are not directly obliged to report under CSRD — and even fewer will be after Omnibus I. But they are increasingly asked for sustainability data by larger customers, banks and tenders. The EU's VSME (Voluntary Sustainability Reporting Standard for non-listed SMEs), published by the European Commission in mid-2025, gives a proportionate template for exactly this. Under Omnibus I, VSME also acts as a practical ceiling on what large companies can demand from their smaller suppliers — so for many Polish SMEs, a clean VSME-aligned inventory is the pragmatic starting point.

National layer: KOBiZE, EU ETS and CBAM

Separate from the CSRD, Poland has a long-standing national emissions regime. Entities whose activity causes emissions to air must file an annual report to the National Centre for Emissions Management (KOBiZE), typically due by the end of February for the prior year. Larger industrial installations are also covered by the EU Emissions Trading System (EU ETS) with verified annual emissions, and Polish importers of carbon-intensive goods (steel, cement, aluminium, fertilisers, electricity, hydrogen) face the Carbon Border Adjustment Mechanism (CBAM), an embedded-emissions exercise closely related to Scope 3. A single emissions backbone lets a Polish company serve all of these from one data set rather than rebuilding the numbers for each.

How to comply: why carbon accounting software

Whether you are obliged under CSRD, answering VSME data requests, or simply building toward both, compliance rests on the same foundation: an auditable greenhouse-gas inventory you can turn into the outputs each framework expects. Spreadsheets rarely survive a limited-assurance review; purpose-built software does. The practical path looks like this:

See how the carbon accounting and reporting modules fit together, and read more on CSRD software for Europe.

Why CarbonTool for Poland

CarbonTool was built for EU reporting obligations, so a company in Poland gets enterprise-grade framework depth with the flexibility to start light and scale up. The fit for the Polish and CEE market comes down to a few things:

Larger Polish groups and multinationals can also explore enterprise carbon accounting software for multi-entity consolidation, and see transparent pricing before committing.