ESG in 2026 — Fewer Companies Required to Report
The CSRD sustainability reporting obligation had been raising mounting concern among Polish companies — implementation costs, audit engagement, detailed environmental data. The amendment to the Accounting Act (Journal of Laws 2026 item 333), in force since March 14, 2026, significantly narrows the scope of entities subject to the obligation. For many mid-sized firms, this is real relief.
What Changed?
The act implements changes from the CSRD directive revision (the Omnibus package), which raised the thresholds for mandatory reporting. The narrowing mainly affects:
- Large entities — previously "first-wave" reporters
- Listed companies, including small and mid-caps, scheduled for subsequent waves
- Capital groups reporting at the consolidated level
New Thresholds — Who Still Must Report?
Sustainability reporting now applies to entities exceeding two of three thresholds:
| Criterion | Threshold |
|---|---|
| Employment | above 1,000 employees |
| Net revenue | above EUR 450M |
| Balance sheet total | above EUR 25M |
Earlier thresholds were considerably lower (e.g., 250 employees, EUR 50M revenue). Thousands of Polish companies that were preparing for ESG reporting are no longer covered.
Relief for First-Wave Reporters
The law provides partial relief for companies that already began reporting for 2024–2025 but no longer meet the new thresholds:
- They may suspend reporting through the transition period
- No obligation to publish a full sustainability statement for 2025
- They must, however, retain documentation of previously collected data
What About Entities Below the Thresholds?
Companies below the thresholds are not obligated to prepare a full ESRS statement. In practice, however:
- Business partners (especially large firms still under CSRD) may require ESG data as part of their supply chain reporting
- Banks and insurers increasingly tie financing terms to the client's ESG metrics
- Voluntary reporting under the simplified VSME standard remains available and can improve competitive position
VSME Standard — Simplified Alternative
For SMEs choosing to report voluntarily, EFRAG prepared the VSME (Voluntary SME Standard). Compared to ESRS, it is:
- Proportionate to company size — fewer indicators
- Modular — mandatory base module, optional extensions
- Accepted by banks as a source of client sustainability data
Practical Steps
- Check the thresholds — is your company still subject to the obligation?
- Review your documentation — if you've been collecting ESG data, retain it for clients and banks
- Assess partner requirements — large firms may demand ESG data regardless of your statutory obligations
- Consider VSME — a voluntary simplified standard can be an attractive compromise
Unsure whether your company is still subject to ESG reporting after the changes? Contact us — we'll assess your situation and help prepare the required documentation.