PFSA and the Polish Ministry of Finance Propose Simplified ESG Reporting – One Plan Instead of Three

The Polish Financial Supervision Authority (PFSA), in cooperation with the Ministry of Finance, has presented a legislative proposal aimed at enhancing the competitiveness of the European Union’s economy, including that of Poland.

One of the key elements of the proposal is the simplification and unification of regulatory requirements related to the preparation of so-called transition plans towards a sustainable economy by companies.

Three directives, one problem: legal uncertainty

Currently, the obligation to develop transition plans stems from three different legal acts:

• the CSRD (Corporate Sustainability Reporting Directive),
• the CRD (Capital Requirements Directive),
• and the CSDDD (Corporate Sustainability Due Diligence Directive).

 The lack of consistency among these regulations has led to legal uncertainty. It remains unclear whether institutions are required to prepare three separate documents or whether a single plan could satisfy the requirements of all three directives.

A single ESG reporting template for all

In response to these concerns, PFSA is proposing the introduction of a unified requirement for the development of a single transition plan aligned with a common informational scope. A central element of this proposal is the definition of a standard template (data checklist) that entities could follow to meet the obligations arising from CRD, CSRD, and CSDDD simultaneously.

For financial institutions, the proposed reference point would be the template contained in Annex I of the European Banking Authority (EBA) Guidelines on the management of environmental, social and governance (ESG) risks. Furthermore, PFSA suggests creating a simplified template for small and non-complex financial institutions, which could significantly reduce their administrative burdens.

Proposed amendments to Directive 2013/34/EU

The proposal also includes an amendment to Directive 2013/34/EU (Article 19a), adding a new paragraph stating that the preparation of a single plan containing the required information would be deemed sufficient to fulfill the obligations under Article 76(2) of the CRD and Article 22 of the CSDDD.

This solution would not only improve the transparency and predictability of regulatory requirements but also significantly reduce compliance costs for supervised entities.

Benefits for the fintech sector

From a fintech perspective, the simplification and harmonization of regulations could be particularly impactful. Firms operating at the intersection of finance and technology often have limited legal resources while facing numerous reporting obligations.

PFSA’s proposals could thus provide meaningful support for building a sustainable yet competitive financial services sector in both Poland and the EU.

Need support with ESG reporting or transition planning?

Get in touch with our Fintech team – we will help you adapt your documentation to the latest requirements and avoid unnecessary regulatory burdens.