Tuesday, 20 October 2026
Poland is preparing to significantly reduce corporate sustainability reporting obligations following government approval of legislative amendments on 20 October 2026. The proposed changes could remove mandatory reporting requirements for a substantial number of businesses, including property developers, construction companies and commercial real estate investors. The reform forms part of Poland’s implementation of revised European Union regulations intended to simplify corporate reporting and reduce administrative costs.
Under the proposed amendments to Poland’s Accounting Act, mandatory sustainability reporting would generally apply to companies employing more than 1,000 people and generating annual net revenue exceeding PLN 1.9 billion. Both conditions would need to be satisfied, with company size assessed over two consecutive financial years. The Polish government estimates that approximately 90% of businesses previously expected to prepare sustainability reports would fall outside the revised requirements.
The changes could be particularly relevant to Poland’s property industry, where businesses frequently manage substantial investment portfolios with relatively small workforces. Residential developers, commercial landlords and property investment companies often rely on external contractors and management firms rather than maintaining large internal teams. Many could therefore fall below the proposed employment threshold, although subsidiaries belonging to larger international groups would still need to consider consolidated reporting obligations.
The reform follows changes introduced through the European Union’s Omnibus I legislative package. Poland has already implemented an initial stage of these measures, with legislation effective from March 2026 providing reporting relief for certain companies covering the 2025 and 2026 financial years. The latest government-approved proposal introduces broader exemptions, generally intended to apply from the 2027 financial year. However, the amendments still require parliamentary approval before becoming law.
Another important element concerns the sustainability information requested from smaller businesses by larger organisations. Companies employing no more than 1,000 people would receive additional protection against extensive information demands arising from corporate reporting obligations. This could reduce administrative work for construction contractors, engineering firms, property managers and specialist service providers. However, larger clients may continue requesting environmental information through commercial agreements and other regulatory requirements.
For commercial property owners and developers, the proposed exemptions would not eliminate existing environmental responsibilities. Building energy performance regulations, environmental permits and other property-related requirements would continue to apply. Banks and institutional investors may also maintain their own sustainability assessment procedures, particularly when financing acquisitions, developments and refurbishment projects. Consequently, energy consumption, emissions and building efficiency are expected to remain important considerations in real estate investment decisions.
The proposed legislation also addresses international corporate groups and investment structures. Revised European rules increase the relevant EU turnover threshold for certain companies headquartered outside the European Economic Area to €450 million, subject to additional conditions concerning their European operations. The amendments also introduce provisions covering commercially sensitive information and financial holding companies. Property investment funds would need to distinguish these corporate reporting changes from separate sustainability disclosure obligations applicable to regulated financial products.
The Polish Ministry of Finance aims to complete the legislative process before the end of 2026, ahead of the European implementation deadline in March 2027. Although the government expects a substantial reduction in reporting obligations, the number of property and construction businesses directly affected has not been established. For Poland’s commercial real estate industry, the reform could lower compliance costs and simplify corporate administration, while leaving the environmental performance of buildings and the sustainability expectations of investors largely unaffected.
