Poland

Member Organizations

Member Organization Associate Other PAOs

  Accountants Association in Poland
  Polish Chamber of Statutory Auditors

Legal and Regulatory Environment

  • Overview of Statuatory Framework for Accounting and Auditing

    Poland is subject to relevant EU regulations regarding the area of corporate financial reporting and subsequently, the EU requirements are transposed into Poland’s national legislation. The key pieces of legislation that establish the accounting, auditing, and financial reporting framework in Poland are:

    • The Accounting Act of September 29, 1994;
    • The Commercial Companies Code of September 15, 2000 (Companies Code 2000);
    • The Act on Statutory Auditors, Their Self-Governing Organisation, Entities Authorized to Audit Financial Statements and on Public Oversight of May 7, 2009 (Act on Statutory Auditors 2009); and
    • The Banking Act of August 29, 1997.

    Accounting Framework

    Poland is subject to EU Regulation EC 1606/2002 and the EU Directive 2013/34/EU which establishes basic requirements for the preparation of financial statements and requires IFRS as endorsed by the European Commission. Under the Accounting Act 1994, IFRS are mandatory for the preparation of consolidated financial statements of listed entities and banks. Listed entities and banks are permitted in some cases to use EU-endorsed IFRS for the preparation of their individual financial statements. Subsidiaries have the option to prepare these in accordance with EU-endorsed IFRS if the parent company prepares its financial statements using the same standards.

    Companies that do not apply IFRS in the preparation of their financial statements are required to follow the accounting requirements included in the Accounting Act 1994 and its by-laws. Under the Accounting Act 1994, the Accounting Standards Committee of the Ministry of Finance is responsible for setting the National Accounting Standards (NAS). In the case where no specific provision exists within the Accounting Act 1994, entities may use NAS, and when these are silent, they may follow EU-endorsed IFRS. There are significant differences between Polish accounting requirements and IFRS. IFRS for SMEs have not been adopted in Poland.

    Insurance companies are also required to prepare their individual and consolidated financial statements in accordance with the accounting requirements of the Accounting Act 1994, as well as with relevant regulations of the Ministry of Finance (Regulation of the Minister of Finance of December 28, 2009 and Regulation of December 12, 2001). In most cases, insurance companies are also given the option to use EU-endorsed IFRS.

    All companies, with the exception of sole proprietorships, are required to file their individual and consolidated financial statements with the Court Register, who makes them available to the public.

    Auditing Framework

    In accordance with the Accounting Act 1994, public interest entities (PIEs), joint-stock companies, and large companies are required to have their financial statements audited. Under the Act on Statutory Auditors 2009, PIEs include listed entities, banks, insurance companies, pension funds, investment funds, brokerage houses, and credit unions. Electronic money institutions are also defined as PIEs, but are not required to have their financial statements audited. Large companies are defined by the Accounting Act 1994 as those which, in the prior financial year, met at least two of the following conditions: (i) 50 full-time employees, (ii) total asset of EUR 2.5 million, or (iii) net revenue of EUR 5 million. Under the Banking Act 1997, listed entities, insurance companies, and banks must submit their audited financial statements to the Polish Financial Supervision Authority (KNF), the oversight authority.

    In accordance with the Act on Statutory Auditors 2009, the Polish Chamber of Statutory Auditors (PIBR)—the professional accountancy organization for auditors and audit firms—is responsible for drafting auditing standards and the Audit Oversight Commission—the public oversight body for the audit profession—must approve them. Clarified ISA have been approved and adopted as the National Standards on Auditing in Poland without modification and effective for the audits of PIEs on December 31, 2016 and for audits of non-PIEs on December 31, 2017. All statutory audits must be conducted by members of the PIBR.

  • Regulation of Accountancy Profession

    In Poland, professional accountants in business and preparers of financial statements are not regulated by law. However, this category of professionals, as well as statutory auditors, may voluntarily join the membership of the Accountants Association in Poland (AAP). Those who join this self-regulated professional accountancy organization are required to have met its membership requirements and to comply with its Code of Ethics. They also become subject to its I&D mechanisms.

    The AAP has developed its own certification programs and confers the titles of Certified Accountant, Chief Accountant, Accounting Specialist, and Accountant based on passing the relevant examinations.

    Statutory auditors, on the other hand, are regulated in accordance with the Act on Statutory Auditors 2009. The Act contains provisions on the certification of auditors and establishes the main responsibilities of the key organizations involved in the regulation of the audit profession. In accordance with this Act, all statutory audits of financial statements must be conducted by members of the Polish Chamber of Statutory Auditors (PIBR). Membership of the PIBR is mandatory for auditors and audit firms.

    In accordance with the Act, PIBR is responsible for: (i) representing its members and protecting their professional interest; (ii) drafting auditing standards; (iii) controlling the proper conduct of the profession and the compliance of PIBR members with ethics standards as well as compliance of entities authorized to audit financial statements with other legal requirements; (iv) cooperating on the development of the accounting and auditing standards; (v) preparing training materials for the candidates to its membership; (vi) conducting publishing and training activities; (vii) maintaining the register for statutory auditors; (viii) conducting quality assurance reviews; (ix) establishing and implementing investigative and disciplinary mechanisms for its members for any breach of rules; and (x) enforcing initial professional development requirements and establishing continuing professional development requirements. The PIBR’s activities are overseen by the Audit Oversight Commission (AOC).

    Candidates for the audit profession are required to meet the detailed education requirements set in the Act on Statutory Auditors 2009. These include holding a university degree, completing a practical experience requirement and passing professional examinations. In order to provide auditing services to the public, qualified individuals must be members of the PIBR and included on its register of auditors that is must maintain. The AOC retains the right to reject the inclusion of a prospective auditor in the register.

  • Audit Oversight Arrangements

    In accordance with the Act on Statutory Auditors 2009, the Audit Oversight Commission (AOC) is responsible for performing public oversight over the practice of the statutory auditors’ profession, operations of entities authorized to perform audits, and the activities of Polish Chamber of Statutory Auditors (PIBR). Its main activities include (i) approving resolutions of the PIBR regarding the adoption of national auditing standards as well as ethics standards, investigation and discipline rules and regulations, and principles of continuing professional development; (ii) supervising the operations of the quality assurance review system conducted by the PIBR’s National Supervisory Committee (NSC) with respect to the audits of public interest entities (PIEs); (iii) conducting its own review of audits of PIEs; (iv) initiating, participating as a party or appealing in relation to disciplinary proceedings conducted by the disciplinary chamber of PIBR; (v) cooperating with international bodies, including in particular with the European Commission, oversight authorities in other EU Member States and third countries; and (vi) registering auditors from third countries.

    The AOC is a member of the International Forum of Independent Audit Regulators.

  • Professional Accountancy Organizations

    In Poland there are two professional accountancy organizations (PAOs), presented below in alphabetical order.

    Accountants Association in Poland (AAP)

    The AAP is a self-regulatory PAO with voluntary membership. Although not legally recognized, the association is the older and larger professional body in Poland. It is actively involved in developing and providing a broad range of courses for the entire accountancy profession, and most members of Polish Chamber of Statutory Auditors (PIBR) are also members of AAP. In accordance with AAP Statutes, the objectives of the association are to deliver training activities and continuing professional development courses to enhance the performance of its members; defending the rights, dignity and interests of its members; ensuring that professional and ethical standards are observed by its members as well as creating adequate conditions for upgrading these standards; further developing and improving accounting practices; and organizing the profession according to the European and global standards.

    The AAP has developed its own certification programs and confers the titles of Certified Accountant, Chief Accountant, Accounting Specialist, and Accountant based on passing the relevant examinations.

    In addition to being a member of IFAC, AAP is a member of the European Federation of Accountants (FEE) and Auditors for Small and Medium Sized Enterprises.

    Polish Chamber of Statutory Auditors (PIBR)

    The PIBR was established under the Act on Publishing Financial Statements and Statutory Auditors of 19 October 1991. This was subsequently replaced by the Act on Statutory Auditors 2009. Membership of PIBR is mandatory for auditors and audit firms. According to the Article 16 of the 2009 Act, the main legal responsibilities of the chamber encompass: (i) representing its members and protecting their professional interest; (ii) drafting auditing standards; (iii) controlling the proper conduct of the profession and the compliance of PIBR members with ethics standards as well as compliance of entities authorized to audit financial statements with other legal requirements; (iv) cooperating on the development of the accounting and auditing standards; (v) preparing training materials for the candidates to its membership; (vi) conducting publishing and training activities; (vii) maintaining the register for statutory auditors; (viii) conducting quality assurance reviews; (ix) establishing and implementing investigative and disciplinary mechanisms for its members for any breach of rules; and (x) enforcing initial professional development requirements and establishing continuing professional development requirements. The PIBR’s activities are overseen by the Audit Oversight Commission.

    In addition to being a member of IFAC, PIBR is a member of the FEE, an Associate Member of the Fédération Internationale des Experts-Comptables Francophones and an Institutional Member of the International Association for Accounting Education & Research.

  • Projects or Other Information

    The Act on Statutory Auditors 2009 is being revised to facilitate the transposition of the EU Directive 2014/46/EU amending EU Directive 2006/43/EC on statutory audits of annual accounts and consolidated accounts. In addition, a large number of World Bank projects are currently being implemented in Poland to further enhance the ongoing development of the profession. These projects include, for example, the implementation of the ROSC: Accounting & Auditing published in 2014, the training of KNF staff on IFRS, and the training of Minister of Finance staff on International Public Sector Accounting Standards.

Adoption of International Standards

  • Quality Assurance

    In accordance with the Act on Statutory Auditors 2009 the Polish Chamber of Statutory Auditors (PIBR) is responsible for establishing and implementing a mandatory quality assurance (QA) review system for all audits. In accordance with the Act, the reviews of public interest entities (PIEs) are subject to the oversight of the Audit Oversight Commission (AOC), which also has the authority to conduct its own QA reviews for PIE audits; however, it does not exercise this right.

    The PIBR’s system employs a cycle approach whereby PIBR’s National Supervisory Committee (NSC) reviews audits of PIEs every three years, and audits of non-PIEs every six years. NSC employs external inspectors approved by the AOC for the review of audits of PIEs, whereas peer reviews can also be used for the reviews of audits of non-PIEs.

    The AOC, which is responsible for approving the quality control standards adopted by the PIBR, approved the adoption of the Clarified International Standard on Quality Control (ISQC) 1 as quality control standards, with effective application for audits of PIEs since January 1, 2016 and for audits of non-PIEs by January 1, 2017 (until then, the former quality control standards, which were also based on a precedent version of ISQC 1, apply). PIBR closely cooperates with AOC to ensure the ongoing development of the QA review system.

    The PIBR reports in its 2017 Action Plan that further development of the existing QA review system is needed to ensure it addresses all SMO 1 requirements.

    Current Status: Partially Adopted

  • International Education Standards

    The Act on Statutory Auditors 2009 sets the main education and certifications requirements for candidates seeking membership to the Polish Chamber of Statutory Auditors (PIBR) while the Accountants Association in Poland (AAP) is permitted by general consensus to establish education and training requirements for its members.

    The AAP has set initial professional development (IPD) and continuing professional development (CPD) requirements for its various categories of members. While AAP has developed membership requirements for Certified Accountants that are in line with the IES requirements, the education requirements for other categories of members (Chief Accountant, Accounting Specialist, and Accountant) do not meet the IES.

    The requirements for candidates for the audit profession as defined in the Act on Statutory Auditors 2009 are in line with the IES according to the PIBR’s 2017 SMO Action Plan. The extent to which the IPD requirements of the IES have been incorporated into the PIBR’s requirements remains to be clarified.

    The Act also stipulates that the PIBR is responsible for adopting CPD requirements and the Audit Oversight Commission must approve them. The PIBR approves CPD providers and universities to deliver professional accountancy education courses. In 2015, the PIBR reports it aligned its CPD requirements with those of IES 7.

    Current Status: Partially Adopted

  • International Standards on Auditing

    In accordance with the Act on Statutory Auditors 2009, the Polish Chamber of Statutory Auditors (PIBR) is responsible for drafting national auditing standards (NSA) and the Audit Oversight Commission (AOC) is responsible for approving them. All statutory audits of financial statements must be conducted in accordance with the NSA.

    The AOC has approved and adopted Clarified ISA as the NSA without modification and effective for the audits of public interest entities (PIEs) on December 31, 2016 and for audits of non-PIEs on December 31, 2017.

    In addition, AOC approved on April 1, 2015 NSCA resolution to adopt the International Standards on Review Engagements and International Standards on Assurance Engagements as national standards. These standards will be applicable for PIEs, for periods ending as from December 31, 2016; for non-PIEs, for periods ending as from December 31, 2017; and for assurance engagements other than audits or reviews of historical financial information started on or after January 1, 2017.

    Clarified ISA and all IAASB pronouncements have been translated by PIBR in accordance with the IFAC Translation Policy.

    Current Status: Partially Adopted

  • Code of Ethics for Professional Accountants

    In accordance with the Act on Statutory Auditors 2009, the Polish Chamber of Statutory Auditors (PIBR) has responsibility for adopting ethical requirements for auditors and the Audit Oversight Commission (AOC) must approve them while the Accountant Association in Poland (AAP) is authorized by general consensus to establish ethical requirements for its members.

    The AOC approved PIBR’s resolution to adopt new ethical standards incorporating the requirements of the 2009 IESBA Code of Ethics with limited modifications. It should be noted that other ethical requirements included in the Act on Statutory Auditors 2009 have precedence over the PIBR’s Code of Ethics; however, it is unclear if provisions in the Act are as or more stringent than the IESBA Code.

    PIBR has translated the 2015 version of the IESBA Code of Ethics and has passed a resolution to adopt this version of the code. However, it is unclear at this time whether this resolution has been approved by AOC.

    The AAP’s Code of Ethics outlines the ethical requirements applicable to its members. AAP’s Code of Ethics was adopted in 2012 and appears to be based on the 2009 version of the IESBA Code of Ethics. AAP states that convergence with the IESBA Code of Ethics is an objective and is following an ongoing process to eliminate differences with the IESBA standards. However, the differences and whether the AAP Code is as stringent as the IESBA Code are unclear.

    Current Status: Partially Adopted

  • International Public Sector Accounting Standards

    The Ministry of Finance (MoF) is responsible for the adoption of public sector accounting standards in Poland. IPSAS have not been adopted and the MoF does not appear to have set the adoption of IPSAS as an objective.

    Additional information about the nature of the public sector accounting standards currently used in Poland is needed.

    Current Status: Not Adopted

  • Investigation and Discipline

    Both professional accountants and auditors in Poland are subject to investigation and discipline (I&D) procedures. In accordance with the Act on Statutory Auditors 2009, the Polish Chamber of Statutory Auditors (PIBR) is responsible for the investigative and disciplinary mechanisms for auditors, pending the approval of its regulations by the Audit Oversight Commission (AOC), while the Accountants Association in Poland (AAP) has adopted self-regulatory rules establishing mechanisms for investigating and disciplining its members for misconduct and breach of the rules.

    The Act on Statutory Auditors 2009 together with additional disciplinary rules adopted by PIBR govern the mechanisms for its I&D system.

    The PIBR reports that its I&D procedures are based on SMO 6 requirements; however, its appeals process must be carried out through an external body according to the Act and only statutory auditors may sit on the Disciplinary Tribunal. In 2015, the PIBR reported that it was developing amendments to its I&D regulations to take into consideration the revised SMO 6 requirements, the responsibilities of the AOC, and amendments to the IESBA Code of Ethics. It is unclear at the time of the assessment whether these amendments have been adopted. As such, the full extent of compliance of the I&D system with SMO 6 revised requirements remains to be clarified.

    The AAP reports that its I&D mechanisms incorporate the major requirements of SMO 6; however, areas of less than full compliance are not known at the time of this report.

    Current Status: Partially Adopted

  • International Financial Reporting Standards

    Poland is subject to EU Regulation EC 1606/2002 and the EU Directive 2013/34/EU, which require the application of IFRS as endorsed by the European Commission. Under the Accounting Act 1994, IFRS are mandatory for the preparation of consolidated financial statements of listed entities and banks. Listed entities and banks are permitted in some cases to use EU-endorsed IFRS for the preparation of their individual financial statements. Subsidiaries have the option to prepare these in accordance with EU-endorsed IFRS if the parent company prepares its financial statements using the same standards.

    Companies that do not apply IFRS in the preparation of their financial statements are required to follow the accounting requirements included in the Accounting Act 1994 and its by-laws. Under the Accounting Act 1994, the Accounting Standards Committee of the Ministry of Finance is responsible for setting the National Accounting Standards (NAS), which provide guidance with respect to the preparation of the financial statements. In the case where no specific provision exists within the Accounting Act 1994, entities may use NAS, and when these are silent, they may follow EU-endorsed IFRS. There are significant differences between Polish accounting requirements and IFRS. IFRS for SMEs have not been adopted in Poland.

    Insurance companies are also required to prepare their individual and consolidated financial statements in accordance with the accounting requirements of the Accounting Act 1994, as well as with relevant regulations of the Ministry of Finance (Regulation of the Minister of Finance of December 28, 2009 and Regulation of December 12, 2001). In most cases, insurance companies are also given the option to use EU-endorsed IFRS.

    Current Status: Partially Adopted

Disclaimer

IFAC bears no responsibility for the information provided in the SMO Action Plans prepared by IFAC member organizations. Please see our full Disclaimer for additional information.

Methodology

Methodology
Last updated: 08/2017
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