Government adopts bill: ESG reporting to cover 90 percent fewer companies

The ESG reporting obligation is to apply only to the largest enterprises. Smaller companies are to receive protection against excessive questions from contractors. However, the bill does not change banks’ expectations toward borrowers.

On Tuesday, 20 October, the Council of Ministers adopted a draft amendment to the Accounting Act. It implements EU Directive 2026/470 from the “Omnibus I” simplification package. ESG reporting, that is, reporting on a company’s impact on the environment, social issues and corporate governance, is to cover only companies and capital groups meeting two conditions. They must employ more than 1,000 people for two consecutive financial years and have more than PLN 1.9 billion in annual net sales revenue. According to the Chancellery of the Prime Minister and the Ministry of Finance, the obligation will cover about 90 percent fewer entities than under the previous regulations.

The bill also limits the data that reporting companies may demand from smaller contractors. From partners employing no more than 1,000 people, they will not be allowed to require information going beyond the voluntary reporting standard. For companies with up to 10 employees, this scope is even narrower. A PCDK study shows that it is still permissible to ask for additional data. However, such a request must be clearly marked, and the smaller company may refuse.

Reports will be allowed to omit trade secrets, classified information, sensitive data, as well as technical knowledge and innovation results. The audit of reports by a statutory auditor remains at the current level of limited assurance. The new rules will apply to the first financial year beginning after 31 December 2026. In companies whose financial year coincides with the calendar year, this applies to reports for 2027.

The narrower statutory obligation does not change banks’ requirements. From 11 January 2026, EBA (European Banking Authority) guidelines require large banks in the EU to take climate, environmental and social risks into account when assessing borrowers. Smaller banks have until 11 January 2027 to do so. Industry studies, including LR.org.pl, indicate that large buyers also include ESG requirements in contracts with suppliers.

A Grant Thornton report shows that for 2025, ESG statements were published by 102 of 407 companies listed on the Warsaw Stock Exchange (25 percent). A year earlier, 154 companies did so (38 percent).

Companies that will no longer be subject to the obligation may still need ESG data in talks with the bank and with key customers.