The EU Corporate Sustainability Reporting Directive (CSRD) was transposed into Polish law through the Financial Act of December 6, 2024, published in the Journal of Laws on December 17, 2024. The Act came into force on January 1, 2025. Although the directive was ultimately implemented, the transposition into national legislation occurred after the official EU deadline of July 6, 2024, resulting in a delay.

Beginning in 2025, approximately 3,800 companies operating in Poland will be required to comply with the CSRD reporting obligations. While large enterprises appear to be relatively well-prepared for the new requirements, small and medium-sized enterprises face significant challenges due to the need for specialised knowledge and financial investments to meet the directive’s standards. Small and medium enterprises will be required to comply with the reporting requirements starting in 2027. 

In terms of differences between the EU Directive and its implementation in Poland, the original directive grants Member States discretion in determining penalties for non-compliance with reporting standards. Poland has adopted a particularly strict approach, introducing high financial penalties and even the possibility of imprisonment for companies and executives that fail to meet the reporting requirements.

The government has not yet released an implementation timeline for the EU Corporate Sustainability Due Diligence Directive (CSDDD), which originally needed to be transposed into national law by July 2026. General information about the CSDDD directive is published on the government’s website, but no details or a precise timeline of implementation are available. With the adoption of the Stop‑the‑Clock Directive in April 2025, the deadline for Member States to transpose the directive was extended by one year to 26 July 2027.

The Government states that despite the increase in reporting regulations, the CSDDD directive will systematise the fragmented national legislation related to due diligence. Polish companies engaged in international business relationships will benefit from the regulatory framework's alignment with European businesses imposed by the regulation. The European Commission will also provide Polish businesses with support in the implementation phase of the CSDDD.

Poland delayed transposing the EU Whistleblower Protection Directive into national law for 3 years. The Directive was officially transposed into national law on 14 June 2024 and entered into force on 25 September 2024. On 25 April 2024, the EU Court of Justice fined Poland a fine of 7 million € for the lack of implementation of the directive into national law and requested an additional 40,000 € for each day of additional delay in transposition.

The new regulations protect individuals who report violations of the law, regardless of their employment status or role. Legal protection will also apply to former employees who report misconduct. The Commissioner for Human and Civilian Rights is the institution responsible for providing support to whistleblowers.

The Polish transposition of the directive implements a broadened scope of reportable violations. Poland allows whistleblowing not only on breaches of EU law but also on constitutional violations, corruption, and human rights abuses.

The Whistleblower Protection Act is the first legal document to protect and define whistleblowers' rights in Poland. The draft bill plans to make the National Labour Inspection responsible for primary report verification.

The EU Directive on Transparent and Predictable Working Conditions was officially transposed into Polish law on 26 April 2023 through the Act of 1 December 2022 amending the Labour Law.

The Directive requires employers to provide employees with information on the conditions of employment relating to their work. The Polish implementation of the directive broadens the scope of this requirement, stating that employers must also inform employees about their right to paid leave and specify the number of days of paid annual leave and other forms of leave. In Poland, the number of paid annual leave days is determined by the number of years of employment. Employees with work experience shorter than 10 years are entitled to a minimum of 20 paid days off, whereas employees with work experience exceeding 10 years are entitled to a minimum of 26 days of paid annual leave. The directive requires employers to provide full information on these varying conditions to the employees.

The EU Directive on Adequate Minimum Wages has not yet been transposed into Polish law. The government is currently working on a bill to ensure that the Directive's requirements are met. The Directive will be implemented into Polish law by amending the Act on Minimum Wages of 10 October 2002.

The draft bill of the amended minimum wage law requires that the minimum wage be revised once a year, as it is currently done (or twice a year in an instance where the inflation rate exceeds 5%). However, a more comprehensive review would be conducted every four years, taking into account factors such as purchasing power and the ratio to the average salary. The first of such extraordinary adjustments is planned for the summer of 2027. This measure aims to ensure that the minimum wage is increased proportionally to the inflation rate.

The government plans to implement the new minimum wage regulations by 2026.

Currently, the minimum wage in Poland is set by the government. In practice, however, an employee’s salary may consist of a base salary combined with other components such as performance-related bonuses or seniority allowances. As a result, the total income of an employee may meet the minimum wage threshold, but their base salary alone may fall below the statutory gross minimum wage. This interpretation of the minimum wage law raises concerns as it contradicts what is intended by the law. It remains unclear whether the implementation of the EU directive into national law will address or eliminate this practice.

The EU Posted Workers Directive was transposed into national law on 30 July 2020. In addition to the Directive on Posted Workers, the General Labour Code protects the rights and labour conditions of all employees in Poland.

The rules imposed by the Directive apply to workers temporarily posted to Poland by employers based in another EU/EEA country and to Polish workers posted abroad by Polish companies. After 12 months (or 18 under specific circumstances), posted workers must be granted full Polish labour rights, not just minimum standards. The National Law Inspector is responsible for monitoring and enforcing compliance with this rule of law. The Polish transposition of the directive is harmonised with the core aspects of the EU Directive. Possible differences might stem only from reporting and digitalisation methods, as they are not standardised and therefore might differ between EU Member States.

The EU Energy Efficiency Directive (EED) was transposed into national law through the Act of 20 May 2016 on Energy Efficiency. Poland has set national targets on energy performance aligned with EU requirements. The Act on Energy Efficiency sets requirements for the renovation of public buildings. To meet minimum energy performance requirements, 3% of the total floor area of central government buildings must be renovated annually. National law also requires energy suppliers to achieve annual energy savings. 

The EU Energy Performance of Buildings Directive is currently being transposed into Polish regulations. No final date of transposition is known yet, however, the Member States must transpose the directive into national legislation by May 29, 2026.  The Ministry of Development and Technology is developing new regulations implementing energy performance of buildings class scales and setting minimum renovation standards aligned with the EPBD objectives.

As part of the National Building Renovation Plan, on February 9, 2022, Poland’s Council of Ministers approved the Long-Term Strategy for Building Renovation. The strategy defines the key measures required to transition Poland’s building sector toward high energy efficiency and low carbon emissions by the year 2050.

The strategy sets both short- and long-term objectives aimed at improving energy efficiency, reducing greenhouse gas emissions, and enhancing air quality. The strategy informs about milestones for 2030, 2040 and 2050. It also outlines a strategic roadmap for the phased modernisation of Poland's existing building structures. In addition to its environmental benefits, the implementation of the regulation is also expected to stimulate job creation in sectors related to building retrofits and thermal upgrades. The large-scale renovation of existing buildings is one of the most significant infrastructure challenges that Poland is facing.

Multiple programmes and subsidies are introduced to achieve the targets of the Energy Efficiency Directive. One of the most notable examples is the ‘Clean Air Programme’’. The objective of the “Clean Air Programme’’ is to improve air quality and reduce greenhouse gas emissions by replacing heat sources and improving the energy efficiency of single-family residential buildings. Individual households that face ‘energy poverty ’ are eligible to apply for the subsidies to replace their heating systems with energy-efficient appliances. This programme aims to support the energy transition efforts and improve the citizens’ housing conditions.

The EU Waste Framework Directive was successfully transposed into Polish law through the Act on Waste of December 14, 2012. The regulations fall under the ‘National Waste Management Plan’. An updated version of the directive entered into force on January 1, 2025. Producers of construction and demolition waste will be obligated to recycle unavoidable waste in the construction process.

The producer of construction and demolition waste is required to ensure the segregation of the waste they generate into at least the following categories: wood, metals, glass, plastics, gypsum, and mineral waste, including concrete, bricks, tiles, ceramic materials, and stones. This aims to ensure the waste is suitable for reuse and recycling, unless segregation is not technologically possible. It is important to highlight that the updated regulations concern primarily businesses and enterprises, not private individuals.

The amended directive raises many concerns among businesses involved in the construction sector, as well as issues concerning waste ownership and the identification of parties responsible for waste management. Currently, the law states that the landholder is the waste holder on the property. This means that if the waste producer cannot be identified, the entity owning the property where the waste is located is responsible.

However, it also opens opportunities for the growth of a new construction-related sector in Poland – a secondary material market for construction components.

Polish Construction Law is the main legal act regulating construction processes in Poland, which entered into force on January 1, 1995. This act defines the principles of design, construction, use, and demolition of buildings. It also contains provisions on construction supervision and the responsibility of designers, contractors, and investors. The construction law states that construction projects must comply with safety, health and environmental protection, energy efficiency, and other requirements. Moreover, the construction law states the regulations regarding building permits and project approvals for construction works.

The Construction Law is regularly updated to ensure that it aligns with EU directives in areas such as environmental protection, energy performance of buildings, and construction waste management. New regulations in areas such as digitalisation or labour laws also influence the amendment of the Construction Law. 

The Regulation of the Minister of Infrastructure on the Technical Conditions to Be Met by Buildings and Their Location is the most important document determining energy efficiency and thermo-modernisation standards for the construction sector. It is regularly amended according to EU regulations. This legal document implements the EU Directive on Energy Efficiency of Buildings, incorporating solutions like Nearly Zero Energy Buildings and Zero Energy Buildings into Polish construction practices.

Moreover, this law specifies technical requirements concerning topics like building construction, noise protection, natural lighting, ventilation, and water and sewage installations. The regulation also sets detailed technical standards for fire protection, minimum distances between buildings and property lines, and access for people with disabilities. This regulation complements the Construction Law and must be followed in all construction and renovation projects across the country.

The preparation of the Long-Term Building Renovation Strategy stems from Article 2a of the Energy Performance of Buildings Directive and the Energy Efficiency Directive. This directive mandates EU Member States to formulate and regularly update national strategies that will help improve energy performance and reduce emissions from the building sector, aiming for a climate-neutral built environment sector by 2050. The Polish Council of Ministers adopted the Long-Term Building Renovation strategy on February 09, 2022. The strategy outlines a roadmap for building renovation in Poland. The aim is to improve the energy efficiency of buildings, reduce GHG emissions and improve air quality. The Strategy also implies the creation of new job opportunities in the retrofitting sector.

The strategy outlines a review of the national building stock. A review of all buildings determined that over 70% of all buildings in the country are characterised by low energy efficiency and require energy and construction renovations. From 2020 to 2030, Poland plans to carry out 236,000 renovations annually. Between the years 2030 and 2040, the target increases to 271,000 buildings per year, and from 2040 to 2050, 244,000 buildings annually are expected to undergo thermal upgrades. Overall, about 7.5 million thermal modernisation projects are planned by 2050, including 4.7 million deep renovations.

The strategy implies both the modernisation of buildings and the replacement of high-emission heating systems. The Long-Term Building Renovation Plan is supported by other programmes for building renovations, including the Clean Air Programme. This plan is supported by both national and EU funds, aligning with the EU’s climate goals under the European Green Deal and the Renovation Wave Strategy.