AmCham position paper on CSRD implementation

AmCham took part in the public consultations regarding implementation of the Corporate Sustainability Reporting Directive into the Polish law. This implementation is made by the draft bill amending the Accounting Act, the Act on Statutory Auditors, Audit Firms, and Public Oversight, among other regulations and affects:

  •  all large entities operating in Poland,
  •  entities that are the parent company of a large group,
  • small and medium-sized entities admitted to trading on a regulated market,
  • certain subsidiaries and branches established in an EU Member State that are controlled by large parent entities.

The main focus of the proposed law is to establish a new non-financial reporting regime. Information on sustainability issues will be more detailed than before. The Bill also introduces mandatory application of European Sustainability Reporting Standards, digitalisation of reporting and mandatory verification of sustainability reporting, including mandatory attestation of reported information by auditors.

The most crucial issue requiring clarification for our member companies is that the proposed law should specify the deadlines for companies within a capital group to fulfill their sustainability reporting obligations, especially when their parent company is based outside the EU. This proposal aims to address the challenges posed by varying deadlines across EU member states, which can complicate compliance for Polish companies reporting through their parent company. The proposal suggests that such reporting should be considered compliant if the Polish company includes a declaration in its financial report specifying which company will publish the required sustainability report and when.

The full document with comments from AmCham member companies is available here.