WHO IS AFFECTED BY CSRD? XBW & EDUS

Who is affected by CSRD?

The non-financial reporting obligation in accordance with the CSRD directive will be introduced for various entrepreneurs gradually in the years 2024–2028 and will cover additional entities as time goes. First of all, the obligation to report in accordance with the CSRD from 2024 was imposed on entities that had already submitted non-financial reports under the NFRD directive. This applies to the largest enterprises, the so-called public interest entities – public companies, banks, and insurance companies. These entities will be obliged to submit reports in accordance with the CSRD Directive in 2025 for the previous year. The purpose of the CSRD is to ensure the consistency and quality of information on sustainability activities provided by these companies. Public enterprises that are subject to the CSRD must provide detailed information on their sustainability activities in their annual reports.

It is worth noting that the CSRD aims to extend the scope of mandatory sustainability reporting also to non-public entrepreneurs. Therefore, submitting reports in 2026 with respect to the 2025 financial year will be mandatory for subsequent large enterprises meeting any two of the three criteria: over 250 employees, over EUR 40 million in turnover, or with a balance sheet total over EUR 20 million.

With respect to the 2026 financial year, non-financial reports in 2027 will be submitted by subsequent groups of entrepreneurs: listed small and medium-sized companies (except micro-enterprises), small and non-comprehensive credit institutions and dependent insurance companies (meeting any two of the three criteria: over 10 employees, balance sheet total above EUR 350,000, or annual revenues above EUR 700,000).

The obligation to submit reports in 2029 in relation to the financial year 2028 is intended for enterprises from third countries if they have a branch in the European Union and generate annual revenues above EUR 150 million.

It is expected that in the future the reporting obligations discussed will be imposed on additional groups of entities.

CSRD and Polish law

Currently, Poland has not yet introduced regulations regarding CSRD as a separate directive. However, Poland is a member of the European Union, which introduces directives on sustainability reporting, such as the CSRD. As a consequence, Poland is obliged to implement the CSRD directive into its legal system within 18 months from the date of its entry into force, i.e., from January 5, 2023. Polish enterprises will have to adapt to the reporting requirements in the field of sustainable development specified in the directive CSRD. It is also worth noting that in Poland there is already legislation on social and environmental reporting, such as the legal Act from October 3, 2008, on the provision of information on the environment and its protection, public participation in environmental protection and on environmental impact assessments. However, the CSRD aims to harmonize and strengthen sustainability reporting standards at the European Union level.

Summary

In summary, there may be some similarities and connections between CSR and CSRD, as CSRD is a tool that aims to support and regulate CSR practices through reporting and transparency requirements. However, it is worth noting that CSR is a broader concept that refers to the entire philosophy of corporate social responsibility, while CSRD refers to specific reporting requirements and regulations.