CSRD and ESG Reporting in 2026 – Who Is Affected and How to Prepare

Who is subject to the reporting requirement in 2026?

The CSRD timeline has been revised numerous times, so it is important to distinguish between the current legal situation and the original plans. The following regulations are currently in effect:

• The largest public-interest entities, which were previously subject to the NFRD (those with more than 1,000 employees and meeting additional financial criteria), were the first to file reports.
• Large companies that were not previously subject to the NFRD—that is,those employing at least 250 employees or with a turnover exceeding 50 million euros or total assets exceeding 25 million euros—will be subject to reporting requirements in the next phase. The deadlines for this phase have been postponed as a result of changes introduced by the Omnibus Package.
• The “Omnibus I” Directive (2026/470)has significantly altered the scope of the CSRD by raising certain thresholds and adjusting the timeline. The largest companies will report under the new rules starting in 2027 if they employ more than 1,000 people and have revenue exceeding 450 million euros.
• Micro- and small enterprisesare exempt from mandatory reporting requirements, in accordance with the definitions set forth in the Accounting Act.

Why does this also apply to companies that are formally exempt?

This is a key, though often overlooked, aspect of the CSRD. The directive introduces a reporting requirement across the entire value chain. Large companies must disclose data on the environmental and social impacts not only of their own operations but also of material parts of their supply chain. In practice, smaller companies—which are formally exempt from this requirement—are often contractually obligated to provide ESG data to larger partners, such as banks, retail chains, or major industrial customers. The lack of this data can lead to exclusion from the supply chain, termination of a contract, or refusal to participate in a tender.

The Three Pillars of the ESG Report (ESRS)

The report, prepared in accordance with the European Sustainability Reporting Standards (ESRS), covers three main areas:

• Environmental (E)– climate change, pollution, water management, biodiversity and ecosystems, circular economy.
• Social (S)– the situation of the company’s own employees and those throughout the value chain, as well as the impact on affected communities, consumers, and end users.
• Corporate Governance (G)– management structures, business ethics, including anti-corruption policies.

Certification Requirement—A New Responsibility for Certified Public Accountants

Sustainability reports must be certified by a certified public accountant or an auditing firm, just as financial statements are. Management boards must ensure effective quality control of ESG data prior to the audit. Data should have an assigned owner, a documented source, a described calculation method, and a complete audit trail, especially with regard to energy, emissions, employee, and financial data.

Transitional Mechanisms You Should Know About

The “quick-fix” mechanism allows companies to omit certain information from their reports for 2025 and 2026, including information on the anticipated financial impacts of certain sustainability-related risks. Companies with more than 750 employees may, during this period, take advantage of some of the transitional provisions originally intended for smaller entities. This is a significant relief for organizations preparing their first reports amid changing regulations.

Why do some companies report voluntarily?

Some organizations, despite being eligible for an exemption from the requirement following the Omnibus amendments, choose to publish a report for practical reasons. These include: continuing reporting that was already underway, expectations from banks financing their operations, pressure from business partners requiring ESG data in the supply chain, and a desire to strengthen the maturity of internal processes before the requirement takes effect.

Practical Steps for Preparing a Business

1. Verify whether your organization is subject to reporting requirements, either directly or indirectly—for example, through contractual requirements imposed by larger partners.
2. Conduct a preliminary gap analysis against the ESRS requirements before time pressure forces you to take hasty action.
3. Designate ESG data owners within the organization, covering energy, emissions, employee data, and financial data related to sustainability.
4. Create an audit trail for the data you collect as early as the preparation stage, regardless of when formal reporting begins.
5. Keep an eye on schedule changes, as deadlines and thresholds may still be subject to adjustment following the implementation of the Omnibus I package.

FAQ

Does a microenterprise have to report on ESG?No. Microenterprises remain outside the scope of mandatory reporting under the CSRD, regardless of the changes introduced by Omnibus I.

Can ESG data be required even in the absence of a formal obligation?Yes. If a company is a supplier or subcontractor to an entity subject to the CSRD, that entity may contractually require the disclosure of ESG data as part of its due diligence in its value chain.

Who is required to certify the sustainability report?A certified public accountant or an auditing firm, in accordance with independence principles analogous to those applicable to the audit of financial statements.

Sources

1. Ministry of Finance,ESG Reporting – New Regulations Implementing the CSRD–gov.pl/web/finanse
2. Prawo.pl,ESG in 2026: What Micro and Small Businesses Must Do–prawo.pl
3. Biznes.gov.pl,Sustainability Reporting–biznes.gov.pl
4. LEX,Corporate Sustainability Reporting Directive (CSRD)–lex.pl
5. Alto Advisory,CSRD – What Is It and Who Will It Affect in 2026? A Guide–altoadvisory.pl

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