CSRD Reporting Poland: A Guide for Polish SMEs

Introduction

Polish small and medium-sized enterprises (SMEs) are becoming increasingly aware of the Corporate Sustainability Reporting Directive (CSRD) and how it affects their position in European supply chains. While most SMEs in Poland will not have to report directly under CSRD, many are being asked for environmental and social data by larger EU clients who do.

This guide explains what the CSRD means for Polish businesses, when it takes effect, and how voluntary frameworks such as the Voluntary Sustainability Reporting Standard for SMEs (VSME) can help you prepare. The goal is to make sustainability reporting achievable—not an administrative burden.

Who Must Report Under CSRD in Poland

According to Directive (EU) 2022/2464, CSRD applies directly to:

• Large companies with 250+ employees, €50 million turnover, or €25 million in assets.
• Listed SMEs on regulated EU markets (except microenterprises).
• Non-EU companies generating €150 million+ turnover in the EU.

Most Polish SMEs are not in scope but will increasingly face data requests from clients and banks. Preparing early through voluntary reporting can strengthen your competitiveness and financing options.

To learn about general thresholds and timelines, see Who Must Report Under CSRD.

Key Dates and National Implementation

Poland is required to transpose CSRD into national law by July 2024. Reporting obligations will apply in phases:

• FY2024 (reports in 2025) – large public-interest entities already subject to the Non-Financial Reporting Directive (NFRD)
• FY2025 (reports in 2026) – other large companies
• FY2026 (reports in 2027) – listed SMEs (with a voluntary opt-out until 2028)

Voluntary application of the VSME standard (EFRAG 2024) is available now for non-listed SMEs that wish to report proactively or satisfy supply chain data requests.

Voluntary Sustainability Reporting for Polish SMEs (VSME)

The VSME Standard developed by EFRAG provides a proportionate, easy-to-use framework for SMEs. It mirrors the European Sustainability Reporting Standards (ESRS) used by large firms but at a simplified level.

Two Reporting Modules

1. Basic Module – Minimum disclosures on key topics such as:

   • Energy and greenhouse gas (GHG) emissions (Scope 1 and 2)
   • Workforce composition, health and safety
   • Anti-corruption and bribery policies (See also how to measure your Scope 1 and 2 emissions).

2. Comprehensive Module – Adds optional metrics for SMEs seeking investment or working with financial institutions.

Why It Matters in Poland

Using the VSME framework helps Polish SMEs:

• Meet data requests from EU supply chain partners.
• Improve access to green financing.
• Build a reputation for transparency and modern management.

You can choose to prepare your sustainability report in Polish or English—but using English is often advantageous for cross-border partners.

Getting Started with CSRD Readiness

1. Map your stakeholders – Identify clients, investors, and banks that may request sustainability data.
2. Collect basic data – Start with energy use, waste, water, and workforce numbers (information typically found in invoices and HR systems).
3. Select your reporting module – For first-time reporters, start with the VSME Basic Module.
4. Set policies and targets – Establish simple internal policies on energy reduction or workforce wellbeing.
5. Prepare your report – Present it alongside your annual financial statement or as a standalone PDF.

For a detailed walkthrough, see VSME Basic vs Comprehensive Module.

Frequently Asked Questions

When does CSRD apply to Polish companies?

Large Polish firms start reporting for financial year 2025, while listed SMEs follow from 2026 (optional until 2028). Non-listed SMEs are not required but encouraged to report voluntarily under the VSME framework to meet client or lender requests. Learn about EU-wide CSRD timelines →

Are there Polish-language resources for CSRD?

Yes. The Ministry of Finance (Ministerstwo Finansów) provides national guidance, and several Polish industry associations offer webinars and templates in Polish. However, most EU-level resources, including EFRAG’s VSME standard, are published in English.

Do Polish SMEs need to report in English?

You may prepare your sustainability report in Polish for domestic use, but English versions are recommended when reporting to EU clients or banks.

How can I simplify data collection?

Start small. Use existing documents—utility bills, payroll summaries, waste invoices—to populate key metrics. As your reporting matures, consider digital automation tools that connect to your accounting or HR systems for ongoing efficiency.

Key Terms

• CSRD – Corporate Sustainability Reporting Directive (EU 2022/2464)
• VSME – Voluntary Sustainability Reporting Standard for SMEs (EFRAG, 2024)
• ESRS – European Sustainability Reporting Standards
• GHG – Greenhouse Gas
• Scope 1 / Scope 2 – Direct and indirect emissions from energy use
• EFRAG – European Financial Reporting Advisory Group

Conclusion / Next Steps

CSRD is reshaping how European businesses demonstrate sustainability, and Polish SMEs are part of this transformation. By adopting the VSME Standard, you can start small, meet your clients’ expectations, and build readiness for future regulations.

Even if your business isn’t yet required to report, voluntary disclosure is a smart investment in resilience and trust. Begin by identifying your key impacts, gathering basic data, and choosing a clear, proportionate framework—VSME makes it practical and accessible.