Supervisor takes interest in reporting

28 Aug 2023
Piotr Biernacki
Sustainability Managing Partner
The Office of the Financial Supervisory Commission addressed a survey to public companies a week ago on various aspects of ESG reporting. It combines elements of supervisory activities and those that relate to future reporting obligations. What implications might the survey have?

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The companies to which the questionnaire was addressed were given very little time to respond (until the end of August), and the scope of information the supervisor wants to obtain is broad. Part of the questionnaire is a fairly straightforward metric to fill out about the basic parameters that determine whether or not a company is subject to mandatory reporting of non-financial information. Another section of the questionnaire deals with the challenges in determining the average annual headcount for a given fiscal year. This, unfortunately, has always been a problem, as both the term employment is inconsistently defined in EU and Polish regulations, as well as the ways of calculating the average are at least several. It can be inferred from the questions asked that perhaps we should expect some attempt to define this issue unambiguously, at least under national law.

The most interesting part of the questionnaire is the part that deals with the challenges of non-financial reporting, Taxonomy disclosures and the upcoming requirements under the CSRD and ESRS standards. The UKNF seeks to identify not only those regulations in place today whose fulfillment raises problems for companies, but also to anticipate the main difficulties associated with the new sustainability reporting regime. The cover letter to the survey indicates that we can expect educational and informational activities from the UKNF in the future, as well as positions taken with regard to the implementation of the new regulations.

Such an initiative on the part of the supervisory authority was sorely lacking when the largest companies listed on the Warsaw Stock Exchange were preparing for non-financial reporting in 2016-2017. Taking action now, a few months before the beginning of the application of the CSRD, I perceive positively. What's more, the education provided by the UKNF on reporting according to the new standards should reach not only listed companies, but also all large companies. After all, large private companies will be subject to the new obligations only a year later.

If you work at a listed company, it is worth spending the next few days telling the supervisor in as much detail as possible what problems you are facing and what challenges you anticipate in the coming months. I hope that the UKNF will publish the conclusions of the collected surveys in the coming weeks. Such a picture of today's state of preparation, even concerning only listed companies, will not only be interesting, but will help wake up those who have not yet started work on adjusting to the new regulations.

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