By 31 December 2026. the largest capital groups must submit the CbC report for 2025 to the Polish National Court Register and publish on their website for the first time.
Legal basis
It is a report that is open to everyone, which, broken down by country (country-by-country), shows the revenues, profit, employment and income tax paid by the group.
The reporting is based on Articles 63l–63o of the Polish Accounting Act (UoR), implementing Directive (EU) 2021/2101.
In accordance with Article 63m(1) of the UoR, the CbC report for 2025 is prepared by certain companies if the threshold was exceeded in each of the last 2 financial years, i.e. in 2024 and 2025 (separately):
- the ultimate parent entity (the company at the head of the group, which prepares the consolidated financial statements) – if the revenues included in its annual consolidated financial statements exceeded PLN 3,500,000,000;
- an independent entity (a company that does not belong to a capital group) – if the revenues included in its annual financial statements exceeded PLN 3,500,000,000.
A separate obligation under Article 63n of the UoR is imposed on a Polish subsidiary or a branch of a group outside the EEA – if in each of the last 2 financial years the consolidated revenues of the group exceeded EUR 750,000,000 and the scale of operations in Poland exceeded 2 of the 3 thresholds set out in Article 3(1)(1b) of the UoR: PLN 33,000,000 of total assets, PLN 66,000,000 of net revenues, 50 people of average annual employment in full-time equivalents; in the case of a branch – if its net revenues exceeded PLN 66,000,000.
The obligation under Article 63m does not apply to groups operating exclusively in Poland (registered office/permanent place of business of all entities).
Polish companies from groups headed by a company from another EEA country may not report on their own – under certain conditions, the parent company in its country submits a report for the entire group.
A non-EEA group company is exempt if the group report is published by the parent company and is filed in the EEA register by the subsidiary or branch indicated therein. The report must be available in at least one official language of the EEA country (Article 63n(7) of the UoR). If the parent company does not provide data, the Polish company reports on the data in its possession.
Report content
The report includes, m.in, a list of subsidiaries, the number of employees, revenues, profit before tax, and tax due and paid. The data are provided separately for each EEA country and for “tax havens” from the EU lists, and for other countries together. A report submitted in Poland (by a Polish company pursuant to Article 63m or Article 63n of the UoR) is prepared in Polish and in PLN (Article 63o(14) of the UoR), in electronic format according to the European Commission’s template (Implementing Regulation (EU) 2024/2952) and is maintained on the website for at least 5 years. A parent company from another EEA country applies the regulations of its country, including in terms of language and currency.
When to submit a CbC report?
- by 31 December 2026 – the CbC report for 2025 must be submitted to the National Court Register and posted on the company’s website, when the financial year coincides with the calendar year;
- within 12 months of the end of the financial year – when the financial year does not coincide with the calendar year.
Sanctions
- failure to prepare a report or unreliable data – a fine, imprisonment of up to 2 years or both together (Article 77 of the UoR);
- failure to submit a report to the National Court Register or failure to publish it on the website – a fine or a penalty of restriction of liberty (Article 79 of the UoR).
