Audit of financial statements in Poland for 2025 – who is subject to the audit requirement and on what terms

For many entrepreneurs operating in Poland, financial statement audits are still associated exclusively with large corporations or listed companies. Meanwhile, more and more medium-sized and smaller companies are subject to mandatory financial statement audits, often without realising it until the end of the year.

Financial statements for 2025, audited in 2026, are prepared according to revised thresholds and rules that have a real impact on the scope of entrepreneurs’ obligations. In this article, we provide a comprehensive explanation of:

• what a financial audit is,
• who is subject to the audit of financial statements for 2025,
• how to correctly assess the audit obligation,
• what are the practical consequences of the audit for the company and its management board.

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Financial audit – what is it and what is its purpose?

A financial audit, also referred to as a financial statement audit, is a process carried out by an independent auditor to verify that the financial statements have been prepared in accordance with applicable regulations and accepted accounting principles. The key elements of an audit are its objectivity and independence – the auditor does not participate in bookkeeping or company management, and their task is to reliably assess the data presented.

During a financial audit, the auditor checks whether the financial statements have been prepared:

• in accordance with the Accounting Act and other applicable regulations,
• based on correctly adopted and consistently applied accounting policies,
• in a reliable and clear manner, i.e. one that faithfully reflects the entity’s financial position, financial performance and financial results.

In practice, a company audit is not limited to a formal ‘check of the numbers’. It also includes an assessment of significant areas of risk, such as the correctness of the valuation of assets and liabilities, the completeness of the recognition of revenues and costs, the validity of provisions, and the correctness of disclosures in the notes. This allows the audit to identify potential irregularities before they develop into more serious legal or financial problems.

One of the most important effects of a financial audit is to increase the reliability of financial data. For owners and partners, this means greater certainty about the reliability of information on the company’s condition. For banks, investors and contractors, it is a signal that the financial statements have been verified by an independent expert and can provide a solid basis for risk assessment and business decisions.

The audit process culminates in an auditor’s opinion, in which the auditor indicates whether the financial statements present a true and fair view of the company’s financial position. Such an opinion not only meets formal requirements, but is also increasingly becoming an element of building trust and transparency in business relations, especially in the case of companies planning to expand, obtain financing or cooperate with larger partners.

HLB Poland provides financial statement audit services in accordance with National and International Financial Reporting Standards. We specialise in auditing companies listed on the Warsaw Stock Exchange, banks and other financial institutions. Contact us to find out how an audit can really support your company.

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Who is always subject to a financial statement audit?

The Accounting Act distinguishes a group of entities that are always subject to a mandatory financial statement audit, regardless of the size of their business, level of revenue or number of employees. In their case, the audit of financial statements does not depend on meeting quantitative thresholds, but results directly from the nature of their activities and their importance for the market and the public interest.

This category primarily includes entities whose activities involve:

• collecting and managing other entities’ funds,
• high levels of systemic risk,
• a particular need for transparency and protection of the interests of customers, investors and market participants.

In practice, this means that financial auditing is a permanent feature of their annual reporting cycle and is mandatory in each financial year.

Entities always subject to audit

Entities that are always subject to financial statement audits include:

• joint-stock companies – regardless of whether they are listed on the stock exchange or remain private companies;
• banks – due to their key role in the financial system and the turnover of funds entrusted to them by customers;
• insurance and reinsurance companies – due to their long-term liabilities to policyholders;
• financial institutions – whose activities are subject to special regulatory supervision;
• entities operating on the capital market, including issuers of securities;
• investment and pension funds that manage capital entrusted to them by participants.

For these entities, auditing the company is not a matter of choice or management decision, but a statutory obligation, the failure to comply with which may result in serious legal and financial consequences.

Why are these entities always subject to audit?

The mandatory audit of financial statements in these cases is intended to:

• ensure maximum transparency of financial data,
• protect the interests of customers, investors and market participants,
• strengthen confidence in the financial system as a whole,
• reduce the risk of fraud and irregularities.

From an entrepreneur’s perspective, it is important to note that in these entities, financial auditing does not depend on the scale of operations or financial results. Even a small joint-stock company or a fund with a limited scope of activity must have its financial statements audited by a certified auditor every year.

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Audit of financial statements for 2025 – new thresholds for other entities

In practice, the most questions and doubts arise regarding the obligation to audit financial statements in the case of limited liability companies, general partnerships and limited partnerships, i.e. entities that are not subject to audit ‘automatically’, but only after exceeding certain statutory thresholds. It is in this group that entrepreneurs most often misjudge their obligations, postponing the issue of financial audit to too late a stage.

For financial statements for 2025, audited in 2026, updated thresholds apply, resulting from legislative changes adapting Polish regulations to EU regulations. This means that an entity is subject to mandatory auditing of its financial statements if, in the year preceding the financial year for which the report is prepared, it met at least two of the following three criteria:

• average annual employment – at least 50 full-time positions,
• total balance sheet assets at the end of the financial year – at least EUR 3,125,000,
• net revenue from the sale of goods and products – at least EUR 6,250,000.

Meeting two of the three conditions means that an audit of the financial statements becomes mandatory, regardless of the wishes of the management board, shareholders or the ownership structure of the company. In practice, this means that even if the company did not plan a financial audit, once the thresholds are exceeded, it is not possible to withdraw from the audit.

The ‘2 out of 3 criteria’ rule – how to understand it in practice?

It is crucial that the legislator does not require all three thresholds to be met simultaneously. It is sufficient to exceed two of them, which in practice means that the obligation to audit the company may arise:

• even with relatively few employees, but high revenues and assets,
• or with a large team of employees and high revenues, despite a lower balance sheet total.

Importantly, entrepreneurs often focus solely on revenues, neglecting to analyse the balance sheet structure or employment levels, which leads to erroneous conclusions about the lack of obligation to audit financial statements.

The previous year – the moment that determines the audit obligation

A very important element that is sometimes a source of misunderstanding is the fact that the obligation to audit the financial statements for 2025 is assessed on the basis of data for the previous year, i.e. 2024.

This means that:

• entrepreneurs should have made a preliminary assessment of whether they would be subject to the audit obligation when closing their books for 2024,
• and failure to do so often results in an ‘unplanned’ audit in 2026.

Thresholds in euros – the importance of the exchange rate

As the thresholds are set in euros, they are converted into Polish zlotys at the exchange rate of the National Bank of Poland on the last day of the financial year. In practice, this means that:

• even with stable financial results,
• a change in the euro exchange rate may cause the thresholds to be exceeded and a financial audit to become mandatory.

No discretion – audit as a statutory obligation

It is worth emphasising that once the thresholds are met, a financial audit ceases to be a business decision and becomes an obligation arising directly from the law. Neither the management board nor the partners:

• may waive the audit,
• may postpone it to the following year,
• may decide that the audit is ‘unnecessary’.

Failure to conduct a mandatory audit of financial statements exposes the entity’s manager to legal and financial liability.

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When should an agreement with an auditor be concluded?

An audit of financial statements is not something that can be planned only after the end of the financial year. According to the applicable regulations, an agreement with an audit firm should be concluded before the end of the financial year to which the audit relates.

This requirement is often overlooked by entrepreneurs, especially in situations where the audit obligation results from exceeding thresholds and was not planned in advance. Meanwhile, concluding a contract after the end of the year may be questioned, and the responsibility for this rests with the entity’s manager, i.e. most often the company’s management board.

In practice, concluding an agreement with an auditor in advance also has an organisational dimension:

• it allows for the planning of the audit schedule,
• it allows for better preparation of financial documentation,
• it reduces the risk of delays and tensions during the audit.

From an entrepreneur’s perspective, a financial audit should therefore not be treated as a ‘problem to be solved after the new year’, but as a process that requires advance planning.

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Who chooses the auditor and why is it important?

Contrary to popular belief, the choice of an audit firm is not the responsibility of the company’s management board. According to the Accounting Act, the auditor is chosen by:

• the body approving the financial statements, most often the shareholders’ meeting or the general meeting of shareholders.

This solution is not accidental. Its purpose is to ensure the independence of the company’s audit and to eliminate potential conflicts of interest.

The auditor who assesses the accuracy of the financial statements prepared by the management board should not be selected or accountable to the same management board.

From the point of view of entrepreneurs, this means the need to:

• properly plan the auditor selection procedure,
• adopt a resolution by the competent body,
• take corporate deadlines into account in the audit schedule.

Failure to follow this procedure may result in the validity of the financial statement audit being questioned.

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Financial audit and other company obligations

In recent years, the audit of financial statements has increasingly been operating in a broader regulatory context. For many entities, financial audit is no longer the only reporting obligation, but has become part of a more complex reporting system.

This applies in particular to:

• ESG reporting under the CSRD Directive,
• new disclosure requirements for financial institutions and investors,
• and the certification of non-financial data, which in practice often involves the involvement of statutory auditors.

For entrepreneurs, this means the need for earlier and more comprehensive planning of reporting processes, as well as better coordination of activities between the finance department, accounting, management and external advisors. In many companies today, the audit of the company is becoming a starting point for organising not only finances, but also reporting processes as a whole.

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What are the consequences of not auditing financial statements?

Failure to conduct a mandatory audit of financial statements is not merely a formal violation. In practice, it can lead to serious legal and business consequences.

Failure to audit financial statements may result in, among other things:

• the imposition of financial penalties,
• criminal liability of the entity’s manager,
• problems with the timely submission of documents to the National Court Register,
• loss of credibility with banks, investors and contractors.

Importantly, in many cases, the costs and consequences of not having an audit are much more severe than the cost of auditing the financial statements themselves. Therefore, a financial audit should be seen not as an unnecessary burden, but as a means of protecting the interests of the company and its management.

HLB Poland audits financial statements of companies from many sectors, including IT, industry, construction and trade. We work with companies listed on the Warsaw Stock Exchange, as well as large private entities and financial institutions. Please contact us if you want to safely plan your financial statement audit.

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Summary – audit as an element of conscious management

The audit of the financial statements for 2025 should not be treated solely as a statutory obligation that needs to be ‘ticked off’. For many companies, the audit of the company is:

• a tool for identifying financial risks,
• an element of building transparency and credibility,
• real support in professional financial management.

A conscious approach to auditing financial statements not only allows you to comply with legal requirements, but also to organise financial processes and prepare your company for further development. Therefore, it is crucial to analyse the audit obligation in advance, plan your cooperation with the auditor properly and make the necessary organisational preparations.

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If you have any further questions or require additional information, please contact your business relationship person or use the enquiry form on the HLB Poland website.

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