The Corporate Sustainability Reporting Directive (CRSD) imposes on selected companies the obligation to report non-financial data. The report prepared based on the European Sustainability Reporting Standards (ESRS standards) will be subject to mandatory attestation by a statutory auditor.
The obligation arises for the largest public companies as early as 2024. The reporting obligation for other large companies, including those that are not public interest entities, arises for the first time in relation to the reporting period starting on 1 January 2025. The first sustainability reporting will take place in 2026.
Who does the obligation to report sustainable development apply to?
The proposed amended Accounting Act defines large companies and parent entities of large capital groups. They are defined as listed and unlisted companies exceeding at least two of the three criteria at the individual or capital group level:
- 250 employees,
- PLN 110 million in total balance sheet assets or
- PLN 220 million in net revenues
For capital groups (before consolidation adjustments) the thresholds are PLN 132 million or PLN 264 million, respectively.
To meet the definition of a large entity or the parent entity of a large capital group, the above thresholds must be exceeded in the reporting period and in the preceding year.
The obligation imposed on companies will include both sustainability reporting (application of the full ESRS) and EU taxonomy reporting (Regulation on the establishment of a framework to facilitate sustainable investment).
The role of the auditor during attestation
Attestation of sustainability reporting for the first few years assumes performing procedures to provide limited assurance.
The procedures will focus on, among others:
- Process of assessing the double materiality analysis, including dialogue with stakeholders,
- Process of collecting information, assessment of completeness of data and methodology of calculating disclosed data,
- Compliance of disclosures with ESRS requirements and EU taxonomy.
The auditor verifies the report and its preparation process through various procedures, including inquiries, analytical procedures and, in selected areas, also verification of source documents.
„Our role begins at the stage of conducting double materiality assessment and determining relevant topics and subtopics. In our opinion, dialogue with the auditor at this stage is very important in order to effectively implement data collection process and preparation the report without surprises.”
Bartłomiej Żołnowski, Certified Auditor
Why us?
During our projects, we ensure an individual approach and commitment to the project. After many years of practice in various projects for the largest domestic and foreign entities, we effectively combine the flexibility and effectiveness of a small team with the corporate work culture.
We organize the process of sustainability attestation in a way to participate in each of the key stages of the sustainability reporting process.
„The role of the auditor is to verify the reported information, but unlike financial reporting, the sustainability reporting process is also assessed on an equal basis with the ESG report. We plan our engagement in such a way as to set milestones and be available at key stages of the process”.
Monika Biniek, Certified Auditor
Our approach
Our approach to performing an ESG report assurance service is based on:
- Early involvement in the reporting process
- Continuous contact and transparent communication with the Company
- Effective management of the attestation process
To achieve this, we have developed a schedule of tasks leading up to the delivery of the attestation report. We propose to divide the work into the following stages:
1. Review of the Company’s double materiality assessment, providing comments/questions to the materiality analysis process regarding identified topics and sub-topics – completeness and documentation of the process.
2. Review and initial assessment of reporting processes, including the Company’s data collection process
3. Design of attestation procedures to address identified risks
4. Conduct preliminary tests on interim data – provide recommendations and observations to the Company and Audit Committee/Supervisory Board
5. Review of report draft for completeness of disclosures
6. Year and review procedures
- Review procedures covering full year data
- Interim procedures update
- Review of full ESG report
7. Communication of identified errors and misstatements
8. Communication with Audit Committee/Supervisory Board
9. Issue of attestation report