Poland

As a member of the European Union, 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, credit institutions, insurance undertakings, and other designated entities. The Ministry of Finance has designated other entities at the national level to include: pension funds; banks; branches of foreign banks; credit unions meeting certain thresholds; electronic money institutions; investment companies; and entities conducting brokerage activity that meet certain thresholds. Listed entities and banks are permitted in some cases to use EU-endorsed IFRS for the preparation of their individual financial statements.

EU-endorsed IFRS have slight modifications from IFRS (e.g., temporary 'carve-out' from IAS 39 Financial Instrument: Recognition and Measurement and a temporary extension of the scope of applying IFRS 9 Financial Instruments with IFRS 4 Insurance Contracts) but according to the IFRS Foundation, the majority of companies can state full compliance with the IFRS.

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. 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.

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 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, must approve the standards. ISAs have been adopted for application in Poland as issued by the IAASB, translated in Polish, and approved by the 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.

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.

Regulation of Auditors

In Poland, the Polish Chamber of Statutory Auditors (PIBR) under oversight by the Public Audit Oversight Agency (PANA), regulates statutory auditors in accordance with the Act on Statutory Auditors, Audit Firms and Public Oversight of 2017 as amended, which is in line with the EU Regulations. The Act on Statutory Auditors, Audit Firms and Public Oversight of 2017 as amended, 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) – i.e., statutory auditors. Membership of the PIBR is therefore mandatory for auditors.

The PIBR is responsible for: (i) certification and registration of statutory 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 (i) maintaining a list of audit firms and a list of audit units from third countries, (ii) conducting quality assurance reviews of audit firms, and (iii) conducting explanatory proceedings, disciplinary investigations and appearing as a prosecutor before courts in cases of disciplinary offenses committed during statutory audits. In turn, the Minister of Finance oversees the activities of PANA.

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 as amended. These include holding a university degree, completing a practical experience requirement, and passing professional examinations before the Examinations Committee which is appointed by the Minister of Finance and administered by the PIBR’s Qualification Procedure Department. To provide auditing services to the public, qualified individuals must be included on the register of statutory 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 voluntarily join a PAO and be subject to its regulation.

The Accountants Association in Poland (AAP) is a voluntary membership association that has developed its own curriculum and certification programs for 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 having practical experience. AAP expects its members to obtain one of the certifications described above, abide by its Code of Professional Ethics in Accounting, and fulfill continuous professional development (CPD) requirements. 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; investigating and disciplining members in any cases of identified violations; further developing and improving accounting practices; and organizing the profession according to the European and global standards.

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

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

Accountants Association in Poland (AAP)

The AAP is a PAO with voluntary membership. 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 the 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; investigating and disciplining members in any cases of identified violations; further developing and improving accounting practices; and organizing the profession according to the European and global standards.

Polish Chamber of Statutory Auditors (PIBR)

The PIBR was established by the Act on Statutory Auditors, Audit Firms and Public Oversight of 1991 as a mandatory membership organization uniting all statutory auditors and audit firms in Poland. Its mission is to ensure the reliability of financial information and the security of business transactions. 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 for certain violations. The PIBR’s activities are overseen by the Polish Audit Oversight Agency (PANA).

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 Professional Accountancy Education Europe (PAEE) (previously the Common Content Project) and of the Fédération Internationale des Experts-Comptables Francophones (FIDEF).

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 overall appears to meet the best practices of SMO 1. It 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.

Additionally, the suite of quality management standards (being a component of SMO 1 – Quality Assurance) issued by the IAASB and effective December 2022 have been translated into Polish by the Polish Chamber of Statutory Auditors’ (PIBR). The resolution on the adoption of the quality management standards was subsequently adopted by the PANA’s Council on November 15, 2022 and became effective on January 1, 2023. Following the resolution’s adoption, the PANA has also amended the quality assurance (QA) review procedures to address the quality management standards. The Inspection procedures in relation to the new quality control standards were updated in April 2023 and formally adopted by the PANA resolution as Policies and procedures for the management of the control system and for carrying out inspections by the PANA (updated April 2023). This material includes: (1) policies and procedures; (2) Appendices to policies and procedures.

Current Status: Adopted

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 before the Examinations Committee which is appointed by the Minister of Finance and administered by the Polish Chamber of Statutory Auditors’ (PIBR) Qualification Procedure Department. Curricula of universities that deliver IPD courses (covering examinations topics) must be approved by the Examinations Committee upon a bilateral agreement.

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). CPD providers that deliver professional accountancy education courses must be approved by PIBR.

PIBR reports that the education requirements (IPD and CPD) are in line with IES issued in 2019.

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; however, the particular version requires clarification. The AAP translated 2019 IES into Polish.

Current Status: Partially Adopted

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, by reference in the NAS, as issued by the IAASB, translated into Polish, and approved by the PANA effective for all audits of financial statements.

PIBR reports that all ISAs within the 2021 Handbook have been adopted for application in Poland an effective date of January 1, 2023.

In May 2023, PIBR’s Council passed the resolution on the adoption of the ISA 600 (Revised) (included at the end of the 2021 Handbook with an effective date of December 2023) with an effective date of January 1, 2026. The resolution awaits approval by the PANA.

Current Status: Adopted

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).

The 2022 International Code of Ethics issued by the IESBA, excluding the Revisions to the Definitions of Listed Entity and Public Interest Entity, has been translated into Polish and adopted by the PIBR with an effective date of September 1, 2023. The resolution awaits final approval by the PANA.

Meanwhile, the Revisions to the Definitions of Listed Entity and Public Interest Entity—which have an effective date of December 15, 2024 in the Handbook— have been translated and the Polish language version will be published on the PIBR website as a separate document. The process of adoption into Polish law will take place at a later stage. Additionally, Revisions to the Code Relating to the Definition of Engagement Team and Group Audits and Technology-related Revisions to the Code are in the process of being translated into Polish.

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 statute to establish ethical requirements for its members.

The AAP reports that its Code of Professional Ethics in Accounting (CPEA) is supplementary to the IESBA Code translated by PIBR to address the fact that its membership is mostly comprised of accountants. AAP indicates that the CPEA is consistent with the IESBA Code.

Current Status: Adopted

The Ministry of Finance (MoF) is responsible for the adoption of public sector accounting standards in Poland. National standards are applied on a partial accrual basis as reported in The International Public Sector Financial Accountability Index developed by the Chartered Institute of Public Finance & Accountancy (CIPFA) and IFAC.

The Accountants Association in Poland (AAP) reports that the MoF is considering the adoption of IPSAS and intends to translate the IPSAS Handbook as a first step.

Current Status: Not Adopted

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 for 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, 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 procedures for AAP 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 mostly aligned SMO 6 and consider 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. AAP has identified a few areas for improvement & alignment with SMO 6 around public interest considerations and regular reviews of the system for effectiveness.

Current Status: Partially Adopted

As a member of the European Union, 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.

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, credit institutions, insurance undertakings, and other designated entities. The Ministry of Finance has designated other entities at the national level to include: pension funds; banks; branches of foreign banks; credit unions meeting certain thresholds; electronic money institutions; investment companies; and entities conducting brokerage activity that meet certain thresholds. Listed entities and banks are permitted in some cases to use EU-endorsed IFRS for the preparation of their individual financial statements.

EU-endorsed IFRS have slight modifications from IFRS (e.g., temporary 'carve-out' from IAS 39 Financial Instrument: Recognition and Measurement and a temporary extension of the scope of applying IFRS 9 Financial Instruments with IFRS 4 Insurance Contracts) but according to the IFRS Foundation, the modifications affect a limited number of companies. Most companies that do not apply the modifications can still state full compliance with IFRS 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. 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. 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.

Current Status: Adopted

Relevant Organizations

• Accountants Association in Poland (AAP)
• Polish Audit Oversight Committee (PANA) (which replaced Audit Oversight Commission (AOC) in 2020)
• Polish Chamber of Statutory Auditors (PIBR)
• Polish Financial Supervision Authority (KNF)
• Accounting Standards Committee (ASC)

Relevant Legislation

• Accounting Act, September 29, 1994, amended 2021
• Statutes of Accountants Association in Poland, January 23, 2009
• Act on Statutory Auditors, Audit Firms and Public Oversight, May 11, 2017, amended in 2019, 2020 and 2022
• Banking Act, August 29, 1997
• Commercial Companies Code, September 15, 2000

Relevant Publications

• Crowe Horwath, Country by Country Financial Reporting and Auditing Framework: Poland, September 2014.
• Deloitte IASPlus website, Poland Jurisdictional Profile, 2009.
• IFIAR, PANA Member Profile, 2022.
• PIBR, SMO Action Plan, 2022.
• AAP, SMO Action Plan, February 2021.
• IFRS Foundation, IFRS Application Around the World, Jurisdictional Profile: Poland, 2016.
• World Bank, Report on Observance of Standards and Codes–Accounting and Auditing: Poland, 2013.
• World Bank, Review of Polish and International Accounting Standards and Scope of Financial Instruments, 2014.
• World Bank, Chamber of Auditors of Poland: Institutional Analysis, 2016.