Poland – Non-financial reporting 2nd NAP

2. Ministry of Development Funds and Regional Policy

Responsible business – promoting due diligence standards

[page 11]

“The issue of due diligence in the field of human rights will also be of particular interest to the Advisory Board for Sustainable Development and Corporate Social Responsibility in view of the legislative changes planned at the EU level as regards due diligence in the area of human rights and environmental issues, as well as in the field of non-financial reporting covering, among others, issues concerning the respect for human rights. Monitoring the directions of legislative changes in non-financial data reporting planned at the EU level, as well as work in areas related to non-financial reporting, constitutes one of the tasks of the Working Group on the Development of Non-financial Reporting established on 31 March 2021”

5.Ministry of Finance

Revision of the Non-Financial Reporting Directive

[page 23)

“The Ministry of Finance is participating in legislative work at the EU level, which commenced after the presentation of the Commission’s proposal on 21 April 2021 and the transmission of all national language versions of the draft legislation, i.e. the draft directive as regards corporate sustainability reporting [COM(2021) 189], to the Member States on 16 June 2021. The Commission’s legislative proposal considerably broadens the scope of entities covered by non-financial reporting – according to the Commission’s estimates from about 12,000 companies to 49,000. Furthermore, the draft clarifies the scope of the reported information, also giving it a new name: sustainability reporting. The key changes proposed in the area of sustainability reporting include:

a. extending the scope of entities subject to sustainability reporting obligation to:

i. all large companies,

ii. small and medium-sized listed companies, which would start reporting three years after largeentities, except for listed micro-companies,

iii. large bodies of undertakings;

b. clarifying the scope of sustainability information to be reported;

c. empowering the EC to adopt uniform European standards on sustainability reporting obligatory for reporting entities; the full standard would be obligatory for large companies, while its simplified version – for small and medium-sized listed companies;

d. removing the possibility to report non-financial information in a separate report that is not part of the management report;

e. introducing an obligation to verify sustainability information;

f. introducing an obligation for companies subject to such reporting to prepare financial statements and management reports in the same format as issuers are obliged to use, i.e. the European Single Electronic Format (ESEF).”

9. Ministry of State Assets

Best practices for WSE-listed and State Treasury (ST) companies

[page 28]

“There are plans to develop best practice recommendations for companies listed on the WSE which, in line with global trends, will emphasise the importance of non-financial capital (e.g. human or environmental capital) used by companies and extend the scope of reporting on non-financial factors. Every year, the Prime Minister issues Guidelines for companies with State Treasury shareholding preparing financial statements, containing information on non-financial reporting (part III of the Guidelines).”