Poland

Member Organizations

Member Organization Associate

  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 1994 as amended, Commercial Companies Code of 2000; Act on Statutory Auditors, Audit Firms and Public Oversight of 2017 as amended, and Banking Act of 1997.

    Accounting

    In line with the EU requirements, Poland requires application of IFRS as endorsed by the European Commission 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.

    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 of 1994. Under the Accounting Act of 1994, the Accounting Standards Committee of the Ministry of Finance is responsible for setting the National Accounting Standards (NAS) - including the guidance how to prepare the financial statements - and for providing recommendations regarding the bookkeeping. Accounting Standards Committee comprises of 15 members of whom for many years 4 members are representatives of the AAP. In the case where no specific provision exists within the Act, entities may use NAS, and when these are silent, they may follow EU-endorsed IFRS. The differences between IFRS and the Polish accounting provisions relate to the technical aspects but the principles and aims of the accounting are similar. NAS indicate these differences. IFRS for SMEs have not been adopted in Poland.

    Insurance companies also are required to prepare their individual and consolidated financial statements in accordance with the accounting requirements of the Accounting Act of 1994, as well as with relevant regulations of the Ministry of Finance (Regulation of the Minister of Finance of December 28, 2009, Regulation of December 12, 2001 and Regulation of the Minister of Finance of April 12, 2016 on the specific provisions relating to the insurance and reinsurance companies). In most cases, insurance companies also are given the option to use EU-endorsed IFRS.

    Auditing

    Public interest entities (PIEs), joint-stock companies, and large companies are required to have their financial statements audited as per the Accounting Act of 1994. Large companies are defined as those which, in the prior financial year, met at least two of the following: (i) 250 full-time employees, (ii) total asset of EUR 2.5 million, or (iii) net revenue of EUR 5 million. PIEs are defined in the Act on Statutory Auditors 2017 and include listed entities, banks, insurance companies, electronic money institutions and payment institutions, pension funds, investment funds, brokerage houses and credit unions.

    In accordance with the Act on Statutory Auditors, Audit Firms and Public Oversight of 2017 as amended, the Polish Chamber of Statutory Auditors (PIBR), the professional accountancy organization for auditors and audit firms in Poland, is responsible for drafting national auditing standards and the Polish Audit Oversight Agency (PANA), the independent public oversight body for the audit profession that became operational from January 1, 2020 replacing the Audit Oversight Commission (AOC), must approve the standards. ISAs have been adopted for application in Poland as issued by the IAASB, translated in Polish, and approved by PANA as national auditing standards effective for the audits of PIEs on December 31, 2016 and for audits of non-PIEs on December 31, 2017.

    Under the Banking Act 1997, listed entities, insurance companies, and banks must submit their audited financial statements to the Polish Financial Supervision Authority (KNF), which has oversight of the banking, capital, insurance and pension sectors, payment institutions and payment service offices, electronic money institutions and credit unions.

  • Regulation of Accountancy Profession

    Only auditors in Poland are legally regulated at the state level. Professional accountants in business, individuals providing accounting services, and other accountancy professionals are not regulated by law but may choose to join a professional accountancy organization (PAO) and be subject to its regulation. There are also not specific requirements related to the persons signing the financial statements. Persons providing accounting services are required to conclude a third-party liability insurance contract for damages caused in connection with their professional activity.

    Regulation of auditors

    In Poland, the Polish Chamber of Statutory Auditors (PIBR) under oversight by the Public Audit Oversight Agency (PANA), which became operational from January 1, 2020 replacing the Audit Oversight Committee, regulates statutory auditors in accordance with the Act on Statutory Auditors, Audit Firms and Public Oversight of 2017 which is in line with the EU Regulations. The Act on Statutory Auditors, Audit Firms and Public Oversight of 2017 contains provisions on rendering auditing services, 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.

    The PIBR is responsible for: (i) certification and registration of auditors; (ii) adopting auditing standards and standards on quality control, (iii) establishing and enforcing ethical requirements as well as continuous professional development (CPD) requirements; (iv) establishing investigation and discipline mechanisms and conducting disciplinary proceedings for certain violations.

    The PIBR’s activities are overseen by the PANA. In addition to supervision of the PIBR, PANA has supervision over audit firms including maintaining a list of audit firms and a list of audit units from third countries, conducting quality assurance reviews of audit firms, conducting explanatory proceedings, disciplinary investigations and appearing as a prosecutor before courts in cases of disciplinary offenses committed during statutory audits. The Minister of Finance oversees the activities of PANA, appoints, and dismisses the bodies of PANA, grants its statute, and approves PANA’s financial statements.

    Candidates to the audit profession are required to meet the detailed education requirements set in the Act on Statutory Auditors, Audit Firms and Public Oversight of 2017. These include holding a university degree, completing a practical experience requirement, and passing professional examinations administered by the PIBR’s Examinations Committee in consultation with the Ministry of Finance. In order to provide auditing services to the public, qualified individuals must be included on the register of auditors that is maintained by the PIBR, complete mandatory continuing professional development and adhere to ethical standards. The PANA retains the right to reject the inclusion of a prospective auditor in the register.

    Regulation of Accountants

    As mentioned above, other accountancy professionals may join a PAO and be subject to its regulation.

    The Accountants Association in Poland (AAP) encourages its members and expects them to obtain one of the certifications described below, abide by its Code of Professional Ethics in Accounting, and fulfill continuous professional development (CPD) requirements. The association investigates and disciplines its members in case of identified violations.

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

  • Audit Oversight Arrangements

    In accordance with the Act on Statutory Auditors, Audit Firms and Public Oversight of 2017, the Polish Audit Oversight Agency (PANA) is responsible for exercising independent public oversight of the auditing profession, including overseeing the activities of audit firms, and statutory auditors whose membership is mandatory in the Polish Chamber of Statutory Auditors (PIBR).

    The PANA, as a national institution, operates fully under the Ministry of Finance. The Minister of Finance is responsible for selecting the head of the Agency and his deputy. The PANA is responsible for (i) oversight of PIBR; (ii) design and implementation of the quality assurance system; (iii) annual plan of inspections PIE audits; (iv) investigation and disciplinary system; and (v) annual report on its oversight activity which are published on the Ministry of Finance website.

    The PIBR is responsible for: (i) certification and registration of auditors; (ii) adopting auditing standards and standards on quality control, (iii) establishing and enforcing ethical requirements as well as continuous professional development (CPD) requirements; (iv) establishing investigation and discipline mechanisms and conducting disciplinary proceedings.

    The PANA is a member of the Committee of European Auditing Oversight Bodies (CEAOB) and the International Forum of Independent Audit Regulators (IFIAR).

  • Professional Accountancy Organizations

    Accountants Association in Poland (AAP)

    The AAP is a self-regulatory PAO with voluntary membership. Although the membership in the association does not guarantee admission to the profession, the association is the oldest and largest professional body of accountants in Poland. It is actively involved in developing and providing a broad range of courses for the entire accountancy profession within certification system and education of accountants, and most members of Polish Chamber of Statutory Auditors (PIBR) also are members of AAP. In accordance with the AAP Statute, 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 certificates of Accountant, Certified Accountant, Chief Accountant, Accounting Specialist, and Certified Expert of Accounting Services and Certified Specialist of Accounting and Tax Bookkeeping based on passing the relevant examinations and practical experience.

    Polish Chamber of Statutory Auditors (PIBR)

    It is mandatory for statutory auditors to be members of PIBR, formerly the National Chamber of Statutory Auditors, which was established by the Act on Statutory Auditors, Audit Firms and Public Oversight of 1991. Under the Act on Statutory Auditors, Audit Firms and Public Oversight of 2017, the main legal responsibilities of PIBR are: (i) certification and registration of auditors; (ii) adopting auditing standards and standards on quality control, (iii) establishing and enforcing ethical requirements as well as continuous professional development (CPD) requirements; (iv) establishing investigation and discipline mechanisms and conducting disciplinary proceedings.

    The PIBR’s activities are overseen by the Polish Audit Oversight Agency (PANA) which started to operate on January 1, 2020.

    In addition to being a member of IFAC, PIBR is a Member of the Visegrad Group composed of Chambers of Auditors from the Czech Republic, Hungary, Slovakia and Poland (V4), an Associate Member of the Common Content Project and of the Fédération Internationale des Experts-Comptables Francophones (FIDEF).

  • Projects or Other Information

Adoption of International Standards

  • Quality Assurance

    In accordance with the Act on Statutory Auditors, Audit Firms, and Public Oversight of 2017 as amended, the Polish Audit Oversight Agency (PANA) is responsible for establishing and implementing a mandatory quality assurance (QA) review system for all audits.

    The PANA’s system employs a cycle approach whereby they review audit firms auditing public interest entities (PIEs) every three years, and audit firms auditing non-PIEs every six years. The reviews are carried out by inspectors employed by the PANA on a contract basis.

    The PIBR reports 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

    Candidates to the audit profession, the only segment of the profession regulated by law, are required to meet the detailed education requirements set in the Act on Statutory Auditors, Audit Firms and Public Oversight of 2017, as amended. These include holding a university degree, completing a practical experience requirement, and passing professional examinations administered by the Polish Chamber of Statutory Auditors’ (PIBR) Examinations Committee in consultation with the Ministry of Finance.

    The law also stipulates that the PIBR is responsible for adopting the continuing professional development (CPD) requirements and that the requirements must be approved by the Polish Audit Oversight Agency (PANA). Universities and CPD providers that deliver professional accountancy education courses must be approved by PIBR. PIBR reports that the education requirements are in line with IES. No details as to the version of the IES that has been incorporated into the national requirements have been provided.

    Other accountancy professionals may join a PAO and be subject to its regulation. The Accountants Association in Poland (AAP) offers its own certification programs and confers the titles of Certified Accountant, Chief Accountant, Accounting Specialist, and Certified Expert of Accounting Services and Certified Specialist of Accounting and Tax Bookkeeping based on passing the relevant examinations and practical experience.

    For the Certified Accountant qualification, the AAP confirms that the initial professional development (IPD) and continuing professional development (CPD) are compliant with IES requirements.

    The AAP translated IES into Polish in 2016 and finalized translation of 2019 IES.

    Current Status: Partially Adopted

  • International Standards on Auditing

    In accordance with the Act on Statutory Auditors, Audit Firms and Public Oversight of 2017 as amended, the Polish Chamber of Statutory Auditors (PIBR) is responsible for drafting national auditing standards (NASs) and the Polish Audit Oversight Agency (PANA) must approve the standards.

    ISAs have been adopted for application in Poland as issued by the IAASB, translated in Polish, and approved by PANA as NASs effective for the audits of public-interest entities (PIEs) on December 31, 2016 and for audits of non-PIEs on December 31, 2017.

    It appears from the information published on the PIBR website that as of 2021 the 2016-2017 IAASB Handbook has been adopted as the NASs. No plans to adopt the 2018 version of ISA have been reported.

    Current Status: Partially Adopted

  • Code of Ethics for Professional Accountants

    In accordance with the Act on Statutory Auditors, Audit Firms and Public Oversight of 2017 as amended, the Polish Chamber of Statutory Auditors (PIBR) has responsibility for adopting ethical requirements for auditors subject to approval of the Polish Audit Oversight Agency (PANA).

    Since 2011, the IESBA Code has been required for application by Polish auditors as translated by the PIBR and approved by the public oversight authority. In 2011, the 2009 IESBA Code was adopted, followed by the adoption of the 2016 IESBA Code in 2018. Finally, effective March 2019, the 2018 IESBA Code of Ethics was translated and adopted for application for auditors in Poland effective May 2019.

    Other than auditors, professional accountants are not legally mandated to abide by ethical requirements. They may, however, choose to become a member of a PAO and be subject to its regulation.

    The Accountant Association in Poland (AAP), which unites professional accountants on a voluntary basis, is authorized by its statue to establish ethical requirements for its members.

    The AAP reports in its 2020 Action Plan that its Code of Professional Ethics in Accounting (CPEA) aligns with the IFAC Code and AAP requires its members to apply ethical principles as detailed in the CPEA. In 2020, the AAP’s Ethics Commission prepared an analysis to detail the similarities between the CPEA and the IESBA Code of Ethics as of March 2019. The report advises that the AAP Code is essentially compatible with the International Code of Ethics for professional accountants issued by the IESBA.

    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. IPSASs have not been adopted and the MoF does not appear to have set the adoption of IPSAS as an objective.

    In Poland, the cash and accrual basis of accounting are used in the public sector as reported in The International Public Sector Financial Accountability Index developed by the Chartered Institute of Public Finance & Accountancy (CIPFA) and IFAC.

    Current Status: Not Adopted

  • Investigation and Discipline

    Both accountants and auditors in Poland are subject to investigation and discipline (I&D) procedures. In accordance with the Act on Statutory Auditors, Audit Firms and Public Oversight of 2017 as amended, the Polish Chamber of Statutory Auditors (PIBR) and the Polish Audit Oversight Agency (PANA) are responsible for the I&D mechanisms for auditors.

    The PIBR conducts disciplinary proceedings against statutory auditors who do not adhere to CPD requirements and for other offenses that are not related to the performance of assurance engagements or in violation of national professional standards. The PANA conducts disciplinary proceedings against statutory auditors for violations and offenses related to the performance of the audit profession other than those which are subject to the PIBR responsibility.

    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.

    Other accountancy professionals are not regulated at the state level but may join a PAO and be subject to its regulation. The Accountants Association in Poland (AAP) has its own regulations specifying the rules and means of proceedings before the peer courts included in its Statute and the by-laws. The rules determine the disciplinary responsibility of the AAP for members who do not adhere to the applicable law, AAP statute, and professional ethics, including the dignity of the accountancy profession and good professional practice.

    The AAP reports that its I&D mechanisms are based on SMO 6 and take into account the specifics of the AAP activity determined by a voluntary nature of the membership and a lack of legal regulation of the accountancy profession in Poland. The exact extent of alignment with SMO 6 needs to be confirmed.

    Current Status: Partially Adopted

  • International Financial Reporting Standards

    Poland is subject to EU Regulations, 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 of 1994 and its by-laws. Under the Accounting Act of 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 some differences between Polish accounting requirements and IFRS. The principles and aims of these two sets of accounting regulations are similar. IFRS for SMEs have not been adopted in Poland.

    Insurance companies also are required to prepare their individual and consolidated financial statements in accordance with the accounting requirements of the Accounting Act of 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: 02/2021
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