On Thursday, November 21, 2024, the Sejm accepted the draft Act amending the Accounting Act, the Act on Certified Auditors, Audit Firms and Public Oversight, and certain other acts, i.e., a set of regulations that are to implement the provisions of the CSRD directive into the Polish legal system. This is not the end of the legislative process. The bill will go to the Senate, which may propose amendments to it. If this happens, the bill would return to the Sejm, which could accept or reject the amendments. Finally, the bill will be sent to the President for signature, who may make various decisions regarding its fate.
I do not expect any difficulties in the further implementation of the CSRD. In my opinion, the adoption of the draft by the Sejm before the end of November significantly increases the likelihood that the new regulations will be published in the Journal of Laws before the end of 2024. I do expect an increase in questions such as „What if they don't make it in time?”, but such questions always arise when EU regulations are implemented in Poland. It is a waste of time to dwell on them; we must work on the assumption that the regulations will be passed (even with a delay, which is already several months).
In addition to the legislative mechanism of general law, another document is being drafted that will be of great importance to companies reporting in accordance with ESRS standards. This is the draft National Standard for Attestation Services other than Examination and Review 3002PL. KSUA3002 will regulate assurance services that provide limited assurance in the field of sustainability reporting.
The Polish Chamber of Statutory Auditors began work on KSUA3002 several months ago. On October 31, 2024, the draft was submitted for public consultation. The consultation was supposed to end on November 15, but the deadline was extended to November 30. So there is still time to submit comments, which I strongly encourage.
Despite the initially very short two-week deadline, MATERIALITY prepared a set of comments on draft KSUA3002. These were submitted as part of a larger package of comments prepared by the Sustainable Development Committee of the Polish Association of Listed Companies.
Why is KSUA3002 so important that everyone preparing a sustainability report should know it inside out? Because it is in accordance with this standard that auditors will certify reports. KSUA3002 will be used during the transition period, i.e., until the European Commission issues standards for assurance services in relation to sustainability reports. This should happen within the next two years or so. For now, therefore, the Polish standard will determine how the auditor should verify whether we have properly conducted the materiality test, whether our report complies with ESRS standards, and whether the data and information contained therein are appropriate. You need to be familiar with KSUA3002 to know how to prepare for cooperation with an audit firm and how the procedures applied by the auditor will proceed.
The system of legal acts and standards regulating sustainability reporting is gradually being finalized. It is worth following the progress in their development, but the most important thing is the implementation of ESRS standards in companies—this takes the most time and raises the most questions 😊
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