Many enterprises cooperate with or are subcontractors of companies that are already
required to publish full ESG reports, which includes carbon footprint reporting at the
Scope 3 level (the entire supply chain).
Therefore, subcontractors who are unable to document their carbon footprint lose
orders to entities with published ESG reports. This means that having an ESG Report
and Strategy has a direct impact on the competitiveness of the company.

• From 1 January 2024 – large public interest companies (employing more than 500
employees) are already covered by the Non-Financial Reporting Directive. This
applies to financial statements for 2024, submitted in 2025.
• From January 1, 2025 – large enterprises that are currently not subject to the Non-
Financial Reporting Directive but meet two of the three parameters will obliged to
report:
1. over 250 employees
2. EUR 40 million turnover
3. EUR 20 million in total assets
They are obliged to submit a non-financial report for the financial year 2025, to be
submitted in 2026.

• From January 1, 2026 – SMEs and other listed companies must report the period
covering financial year 2026, filing in 2027. SMEs can defer ESG reporting until 2028.

Non-financial reporting is already a requirement among financial institutions. This
may mean the inability to obtain loans, worse financing conditions and investor
support withdrawal. At the same time, the lack of an ESG report may result in less
interest from institutional investors, reducing the value of the company’s shares,
which directly translates into financial returns.

Pursuant to Art. 28 all CSRD Member States are to establish national provisions under which sanctions may be imposed for failure to comply with the obligations arising from the Directive, unless infringements covered by the CSRD are subject to sanctions under national law, in which case Member States may decide not to introduce provisions regarding administrative penalties for infringements that are already subject to national criminal law. In such a case, they shall inform the Commission of the relevant provisions of criminal law. The Polish Financial Supervision Authority (KNF) is responsible for verification and supervision of the implementation of CSRD obligations.

The regulatory obligation will apply to most companies from 2025. A preparatory start is
necessary because the process of collecting data and changing business processes is time-
consuming. When the report is subject to audit, the company is obliged to collect all data and
implement business processes to ensure proper execution of the report. Company
management often point out the complexity of ESG reports and the need to transform the
company’s ESG. Therefore, action should be taken immediately so that ESG reports can be
prepared with due care and quality.

CSRD requirements apply to all entities regardless of the consolidated results of the capital
group. Therefore, if any entity within the capital group meets the CSRD reporting
requirements, then that entity is obliged to prepare an ESG report.

The provisions related to the CSRD foresee such scenarios, and it’s not necessary to prepare
individual reports for each daughter company that meets the CSRD requirements. The
regulations allow the preparation of a consolidated ESG report at the capital group level,
which is a significant convenience for many enterprises.