Audit in Poland: a step-by-step financial statement audit guide

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What should a company know about a financial statement audit in Poland?

An audit in Poland should be planned before the financial year ends. A company must first determine whether a statutory audit is required, appoint an authorised audit firm early enough for the auditor to observe material inventory counts, prepare its financial and corporate documentation, and coordinate the audit with the year-end closing process.

For many entities, a statutory audit becomes mandatory when at least two of three thresholds were met in the preceding financial year: 50 full-time equivalent employees, EUR 3.125 million in total assets or EUR 6.25 million in net revenue from the sale of goods and products.

The annual financial statements must generally be approved within six months of the balance sheet date and filed with the National Court Register within 15 days of approval. Foreign-owned companies should also align the Polish statutory audit with group reporting, consolidation packages and International Financial Reporting Standards requirements.

An audit in Poland is not a process that should begin after the accounting books have already been closed. Management should determine the audit requirement, appoint an audit firm and establish the reporting timetable before the end of the financial year.

Companies seeking support with the process can engage HLB Poland for financial statement audit services in Poland, including audits of Polish subsidiaries operating within international corporate groups.

For management, an audit is more than a statutory formality. It tests the reliability of financial data, the quality of the year-end closing process, the effectiveness of internal controls and the flow of information between accounting, tax, operations and group headquarters.

Starting early reduces the risk of late adjustments, missed deadlines and disputes immediately before the financial statements are submitted for approval.

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What is a financial statement audit in Poland?

A financial statement audit in Poland is an independent examination of a company’s annual financial statements by a statutory auditor acting on behalf of an authorised audit firm.

The auditor’s objective is to obtain reasonable, rather than absolute, assurance that the financial statements are free from material misstatement.

In practice, the auditor does not examine only the final figures shown in the balance sheet and income statement. The audit also covers how those figures were produced, including:

• the completeness and accuracy of the accounting records;
• the quality of supporting documentation;
• accounting estimates and provisions;
• financial statement disclosures;
• the company’s accounting policies;
• the valuation of assets and liabilities;
• areas in which the risk of error or manipulation is higher.

For foreign-owned companies, a financial statement audit in Poland usually has an additional dimension. The local statutory process may need to be coordinated with group reporting instructions, consolidation packages, headquarters’ deadlines and differences between the Polish Accounting Act and International Financial Reporting Standards (IFRS). The local audit and the group reporting process may overlap, but they are not interchangeable.

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When is a company required to undergo a statutory audit in Poland?

A company must undergo a statutory audit when the obligation arises under the Polish Accounting Act or under separate sector-specific regulations.

Some entities are subject to an annual audit regardless of their size. Others become subject to the requirement only after meeting at least two statutory thresholds.

Entities whose annual financial statements are generally audited regardless of the thresholds include, among others:

• banks and branches of credit institutions;
• insurance and reinsurance undertakings;
• entities operating under securities trading and investment fund regulations;
• pension funds;
• certain payment institutions and electronic money institutions;
• joint-stock companies, except companies in formation at the balance sheet date;
• annual consolidated financial statements of corporate groups;
• entities preparing annual financial statements under IFRS.

The complete scope of the requirement is set out in Article 64 of the Polish Accounting Act.

For companies that are not automatically subject to an audit, management must examine the financial and employment data from the financial year preceding the year covered by the financial statements.

A common mistake is to analyse the audit requirement only after the financial year has closed. At that point, the company may have limited time to appoint an audit firm, pass the necessary corporate resolution and arrange for the auditor to observe the inventory count.

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What financial statement audit thresholds apply in Poland?

For many entities continuing as a going concern, the audit requirement arises when at least two of the following three conditions were met in the preceding financial year.

Statutory criterion	Audit threshold
Average annual employment	At least 50 full-time equivalent employees
Total balance sheet assets at year-end	At least the PLN equivalent of EUR 3,125,000
Net revenue from the sale of goods and products	At least the PLN equivalent of EUR 6,250,000

Meeting two out of the three conditions means that the annual financial statements are subject to a statutory audit.

These thresholds apply to financial years beginning after 31 December 2024. They should be assessed using data from the preceding financial year. Management should complete this assessment before the financial year ends. The audit agreement must be signed early enough for the audit firm to participate in the inventory count of material assets where such attendance is required.

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How does a financial statement audit in Poland work step by step?

A well-managed audit does not begin when the accounting department sends the general ledger to the auditor. It begins with an assessment of the statutory requirement, a year-end timetable and clear allocation of responsibilities within the company.

Step 1: Is the company subject to a mandatory audit?

The first step is to determine formally whether the company’s annual financial statements must be audited.

Management should examine:

• the company’s legal form;
• the nature and regulatory status of its business;
• any industry-specific requirements;
• its financial data for the preceding year;
• its average number of full-time equivalent employees;
• whether the company prepares its statements under the Polish Accounting Act or IFRS.

Companies belonging to international groups should also establish whether an audit is required by group headquarters, a financing bank, an investor or internal corporate procedures.

Such an audit may not be required directly under Polish legislation but may still be contractually or commercially necessary.

Step 2: How should the company select an audit firm in Poland?

A financial statement audit must be performed by an audit firm authorised to conduct statutory audits in Poland.

The Polish Agency for Audit Oversight (PANA) maintains the official list of audit firms. The Polish Chamber of Statutory Auditors (PIBR) provides access to the register of statutory auditors maintained by the National Council of Statutory Auditors.

Price should not be the only selection criterion. Management should also consider whether the proposed audit team understands the company’s industry, reporting framework and group structure.

Selection criterion	Why it matters to the company
Entry on the PANA list	Confirms that the audit firm is authorised to conduct statutory audits in Poland
Relevant industry experience	Helps the auditor identify sector-specific risks in areas such as manufacturing, retail, technology, real estate or financial services
Group reporting experience	Supports coordination between the Polish statutory audit and headquarters’ consolidation requirements
English- or German-language communication	Important where shareholders, management or the group auditor are based outside Poland
Knowledge of Polish accounting and IFRS	Helps identify differences between local statutory accounts and group reporting
Availability before year-end	Enables the auditor to attend material inventory counts and conduct interim procedures
Appropriate team capacity	Reduces the risk of delays during the final audit stage

For a foreign-owned company, the audit firm should also be able to communicate effectively with the parent company and, where necessary, respond to instructions issued by the group auditor.

Step 3: Which corporate body appoints the audit firm?

The audit firm should be selected in accordance with the Polish Accounting Act, the company’s articles of association and any other rules binding on the entity.

As a general rule, the body responsible for approving the annual financial statements selects the audit firm. Depending on the company’s legal form and constitutional documents, this may be:

• the shareholders’ meeting;
• the general meeting of shareholders;
• a supervisory body;
• another body expressly authorised under the company’s governing documents or applicable legislation.

The company’s management board normally signs the engagement agreement on behalf of the entity, but it should not make the formal appointment where Polish law assigns that decision to the approving body. The corporate resolution should therefore be planned early enough to avoid delaying the engagement.

Step 4: When should the audit agreement be signed?

The agreement must be signed early enough for the audit firm to participate in the inventory count of material assets.

For a statutory audit, the first engagement agreement with an audit firm must be concluded for a period of at least two years. It may subsequently be extended for further periods of at least two years.

This timing is particularly important for companies with:

• significant inventories;
• multiple warehouses;
• valuable fixed assets;
• complex production processes;
• goods held at third-party locations;
• material work in progress.

An agreement signed after the inventory count may prevent the auditor from performing the planned observation procedures. Alternative procedures may be possible in some cases, but they can increase the amount of work, extend the audit and create additional risk.

Step 5: What should be included in the audit timetable?

After the agreement has been signed, the company and the audit firm should establish a detailed schedule.

The timetable should normally cover:

• interim audit procedures;
• inventory count dates;
• the accounting close;
• delivery of the trial balance and supporting schedules;
• preparation of the draft financial statements;
• deadlines for confirmations from banks, customers and suppliers;
• the final audit period;
• management and supervisory board meetings;
• the planned financial statement approval date;
• filing with the National Court Register.

For a Polish subsidiary, the local timetable should also be compared with the reporting calendar issued by the parent company.

A group may require its consolidation package before the Polish statutory deadline. Unless these timetables are coordinated, the finance team may be forced to prepare different versions of the same data under significant time pressure.

This increases the risk of inconsistencies between the local statutory accounts, the consolidation package and the figures reviewed by the group auditor.

Step 6: What documents and data should be prepared for the auditor?

The auditor requires more than the final financial statements. The company must provide an audit trail showing how the amounts and disclosures were calculated.

The documentation usually includes:

• the trial balance;
• general ledger and subledger extracts;
• account reconciliations;
• fixed asset registers;
• inventory records and count sheets;
• bank confirmations;
• trade receivable and payable confirmations;
• significant commercial agreements;
• loan and lease agreements;
• provisions and accrual calculations;
• deferred tax calculations;
• related-party transaction documentation;
• information on legal disputes;
• guarantees and contingent liabilities;
• tax returns and reconciliations;
• group reporting packages.

The company should establish one controlled document repository with consistent file naming, version management and designated owners for each audit area.

Disorganised file exchange is one of the most frequent causes of delay. It also makes it difficult to determine whether the auditor has received the final version of a document.

Step 7: What happens during the interim audit?

The interim audit enables the auditor to understand the company’s business, accounting processes, control environment and areas of increased financial reporting risk.

The auditor may review processes relating to:

• sales and revenue recognition;
• purchasing and accounts payable;
• inventory management;
• fixed assets;
• payroll;
• tax;
• treasury;
• financial reporting;
• consolidation and intercompany reconciliation;
• information systems and access controls.

For management, this is the best stage at which to identify issues before the final audit.

Potentially difficult areas should be discussed early. Examples include slow-moving inventory, impairment, long-term contracts, complex revenue arrangements, significant provisions, restructuring costs or material accounting estimates.

Leaving these matters until the final audit may result in late adjustments affecting profit, banking covenants, group reporting or draft shareholder resolutions.

Step 8: What is the auditor’s role during the inventory count?

Where a company holds material inventories or other assets subject to physical verification, the auditor should be given an opportunity to attend selected inventory count procedures.

The auditor does not perform the inventory count for the company. Responsibility for organising, conducting and documenting the count remains with the audited entity. The auditor observes selected procedures, performs test counts and evaluates whether:

• the count instructions are appropriate;
• inventory movements are controlled;
• damaged and obsolete items are identified;
• test counts agree with the count sheets;
• the final results are correctly reflected in the accounting records.

The company should inform the auditor in advance of all material locations and count dates, including inventories stored with external logistics providers or subcontractors.

Step 9: How should the company close its books and prepare the draft financial statements?

After the financial year ends, the company prepares a draft set of annual financial statements.

The finance team should verify consistency between:

• the balance sheet;
• the income statement;
• the notes to the financial statements;
• the cash flow statement, where required;
• the statement of changes in equity, where required;
• the management report, where applicable.

Preparing financial statements is not merely a technical process of generating an electronic file from the accounting system.

Management must ensure that:

• the accounting policies are current;
• all material year-end entries have been posted;
• balances are reconciled;
• estimates are documented;
• disclosures are complete;
• comparative information is correct;
• figures appearing in different sections of the statements are consistent.

The notes should be prepared in parallel with the year-end close. Leaving all disclosures until the final stage frequently creates avoidable delays.

Step 10: What happens during the final audit?

The final audit involves detailed procedures relating to financial statement balances, transactions and disclosures.

Depending on the company’s circumstances, the auditor may test:

• valuation of assets and liabilities;
• revenue recognition;
• completeness of expenses and liabilities;
• inventory valuation;
• impairment allowances;
• provisions;
• deferred tax;
• related-party transactions;
• foreign currency balances;
• events after the balance sheet date;
• going concern assumptions;
• presentation and disclosure requirements.

Where the auditor identifies an error or omission, the company may be asked to:

• post an accounting adjustment;
• revise an estimate;
• expand a financial statement disclosure;
• provide additional supporting documentation;
• explain a transaction or unusual balance.

Late audit adjustments are particularly disruptive when they affect the reported result, bank covenants, group reporting, management bonuses or resolutions already prepared for shareholders.

Step 11: What is issued when the audit is complete?

At the end of the audit, the audit firm issues an independent auditor’s report.

The report contains the auditor’s opinion on whether the financial statements provide a true and fair view in accordance with the applicable financial reporting framework.

The financial statements, together with the auditor’s report and other required documents, are then submitted to the appropriate corporate body for approval.

Depending on the entity, the documents filed may include:

• the annual financial statements;
• the resolution or decision approving the statements;
• the resolution on the allocation of profit or coverage of loss;
• the independent auditor’s report;
• the management report, where required;
• other documents required for the particular entity.

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When must audited financial statements be approved and filed in Poland?

Annual financial statements should generally be approved within six months of the balance sheet date.

For a company whose financial year corresponds to the calendar year, the standard approval deadline is therefore 30 June.

The approved financial statements and the accompanying documents must then be filed with the National Court Register (KRS) within 15 days of approval. The National Court Register is Poland’s central judicial register for companies and other registered entities. The filings are submitted electronically to the Financial Document Repository.

A delay in completing the audit can therefore affect not only the audit timetable but also the scheduling of the shareholders’ meeting and the company’s ability to meet the filing deadline.

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How long does a financial statement audit take?

The duration of an audit depends on the size and complexity of the company, the quality of its accounting records and the readiness of its employees to respond to audit requests.

A small or medium-sized company with reconciled accounts and well-organised documentation may complete the process relatively efficiently.

A manufacturing, retail, regulated or internationally owned company will usually require more time due to factors such as:

• significant inventory balances;
• multiple locations;
• long-term contracts;
• related-party transactions;
• foreign currency settlements;
• financial instruments;
• complex tax positions;
• group reporting requirements.

Audit stage	Typical timing	Main cause of delay
Assessment of the audit requirement	Before financial year-end	Thresholds and legal form analysed too late
Appointment of the audit firm	Before material inventory counts	Missing corporate resolution or delayed engagement agreement
Interim audit	Before the year-end close	Unclear responsibilities and undocumented processes
Inventory observation	Around the balance sheet date	Incomplete count instructions or failure to notify the auditor
Final audit	After preparation of the draft statements	Adjustments, missing disclosures and unreconciled balances
Approval and filing	After the audit is completed	Delayed corporate meetings or incomplete filing documents

The company can reduce the overall duration by resolving accounting issues during the interim audit rather than waiting for the final stage.

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What documents are needed for a financial statement audit in Poland?

The precise list depends on the company’s activities, risk profile and accounting framework. The audit firm will normally issue a detailed request list, but management should prepare the core documentation in advance.

Which financial documents are normally required?

The financial documentation commonly includes:

• draft annual financial statements;
• trial balance;
• general ledger and subledgers;
• account reconciliations;
• VAT registers;
• corporate income tax calculations;
• current and deferred tax reconciliations;
• bank statements and confirmations;
• receivable and payable confirmations;
• fixed asset registers;
• inventory documentation;
• accrual and prepayment schedules;
• provision calculations;
• impairment assessments.

The auditor may also request transaction-level samples and supporting invoices, contracts, acceptance documents or payment records.

Which corporate and legal documents may be requested?

The company should be prepared to provide:

• articles of association;
• current National Court Register information;
• shareholder resolutions;
• minutes of management and supervisory board meetings;
• information on changes in share capital or ownership;
• material commercial agreements;
• loan and financing agreements;
• lease agreements;
• guarantees and security documents;
• information on legal and administrative disputes;
• correspondence with regulators where relevant.

Minutes and resolutions are important because they may contain information about dividends, restructuring plans, financing decisions, litigation, business combinations or events after the reporting date.

Which operational documents may be relevant?

Depending on the industry, the auditor may request:

• warehouse reports;
• inventory count sheets;
• production cost calculations;
• customer contracts;
• delivery terms;
• acceptance protocols;
• project profitability reports;
• sales system extracts;
• production system data;
• logistics reports;
• evidence supporting revenue cut-off.

Operational data should be reconciled with the accounting records before it is submitted to the auditor.

Which group reporting documents are needed for a foreign-owned company?

A Polish subsidiary may also need to provide:

• the group consolidation package;
• group accounting instructions;
• intercompany confirmations;
• related-party reconciliations;
• information on group financing;
• IFRS conversion schedules;
• reconciliation between local statutory figures and group reporting;
• instructions received from the group auditor.

The local finance team should clearly identify which adjustments apply only to group reporting and which must also be reflected in the Polish statutory accounts.

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Is the auditor responsible for preparing the financial statements?

No. Responsibility for preparing the financial statements remains with the company’s management, legally referred to as the head of the entity and usually represented by the management board.

The auditor examines the statements and issues an independent auditor’s report. The auditor does not assume responsibility for:

• maintaining the accounting books;
• selecting the company’s accounting policies;
• making management estimates;
• approving provisions;
• determining the company’s business assumptions;
• preparing management representations;
• ensuring the completeness of source documentation.

This distinction is particularly important in foreign-owned companies. Group headquarters may assume that the Polish auditor will organise the entire year-end close or correct the company’s accounting records.

The audit is most efficient when the company has already prepared and reviewed its data and the auditor can focus on independent verification.

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How can management reduce the risk of audit adjustments?

The most effective approach is to resolve the areas that typically create the greatest audit risk before the final audit begins.

Management should focus on:

• inventory;
• revenue recognition;
• provisions and accruals;
• impairment allowances;
• fixed assets;
• related-party transactions;
• tax;
• deferred tax;
• financial statement disclosures;
• going concern assumptions.

Before the audit, management should ask the following questions:

• Is the company’s accounting policy up to date?
• Have all material agreements been provided to the accounting team?
• Have sales, logistics and warehouse records been reconciled at year-end?
• Are provisions and estimates supported by documented business assumptions?
• Has management reviewed events occurring after the balance sheet date?
• Are group reporting figures consistent with the local statutory accounts?
• Have intercompany balances been agreed with all group counterparties?
• Does management know which areas may require additional audit evidence?
• Have all material tax positions been reviewed?
• Are the notes to the financial statements being prepared alongside the accounting close?

International companies should appoint one person to coordinate communication between local accounting, management, the Polish auditor and group headquarters.

Without a clear process owner, audit questions frequently circulate between departments without a complete or timely response.

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What are the most common organisational mistakes during an audit?

The most serious audit problems rarely arise simply because the company is subject to an audit. They arise because the process starts too late or is treated as an administrative formality.

Common mistake	Consequence for the company	How to prevent it
Audit requirement assessed too late	Time pressure when appointing the auditor	Review the legal form and thresholds before year-end
No formal resolution appointing the audit firm	Procedural risk and delayed engagement	Include the appointment in the corporate calendar
Audit agreement signed after inventory counts	Difficulty obtaining sufficient evidence for inventory	Appoint the auditor before material counts take place
Documents stored across multiple systems and inboxes	Slow responses and version-control problems	Use one controlled repository with designated owners
No coordination with group headquarters	Inconsistencies between local and group figures	Establish one local and group reporting timetable
Accounts not reconciled before submission	Repeated audit questions and additional testing	Complete balance sheet reconciliations before the final audit
Incomplete financial statement disclosures	Late revisions to the financial statements	Prepare the notes alongside the year-end close
No central audit coordinator	Requests circulate between departments	Appoint one person responsible for the audit process

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What is different about auditing a foreign-owned company in Poland?

A foreign investor may find that the Polish audit process differs from the procedures used in the parent company’s home jurisdiction.

Differences may concern:

• the required electronic format of the financial statements;
• the role of the shareholders and other corporate bodies;
• the formal appointment of the audit firm;
• the approval timetable;
• filing with the National Court Register;
• Polish accounting rules;
• the relationship between local statutory reporting and IFRS.

In practice, foreign-owned companies should distinguish between three reporting levels:

1. Local statutory financial statements prepared under the Polish Accounting Act or another permitted reporting framework.
2. The Polish statutory audit performed by an audit firm authorised in Poland.
3. Group reporting prepared for the foreign parent company and consolidation process.

These processes should be coordinated, but they are not the same.

The Polish auditor examines the financial statements prepared under the reporting framework applicable to the local company. Group headquarters may require a separate package based on IFRS, US GAAP or another group accounting policy.

As a result, the company may need a documented bridge between local accounting figures and the group package. This bridge should explain:

• accounting policy differences;
• consolidation adjustments;
• differences in materiality;
• reclassifications;
• group-only provisions;
• reporting currency adjustments;
• timing differences between local and group closing.

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Can an audit help management improve the company?

Yes, provided the company treats the audit as part of its financial risk management process rather than only as a statutory obligation.

An audit may identify weaknesses in:

• source data;
• account reconciliations;
• approval procedures;
• documentation of estimates;
• information exchange between departments;
• year-end closing controls;
• financial statement disclosures;
• group reporting processes.

The auditor does not replace the accounting team, financial controller or tax adviser. Nevertheless, an effective audit gives management a structured view of the areas that may affect the reliability of the company’s financial reporting.

For businesses seeking bank financing, new investors, a sale of shares or further expansion in Poland, audited financial statements can also strengthen confidence among shareholders, lenders and business partners.

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How should a company prepare for an audit in Poland?

Before the audit begins, the company should conduct an internal readiness review.

This does not need to become a separate, complex project. It should, however, cover the key legal, accounting and organisational responsibilities.

Audit readiness checklist for management and finance teams

• Confirm whether the company is subject to a statutory audit.
• Identify the corporate body authorised to appoint the audit firm.
• Pass the required appointment resolution.
• Sign the audit agreement before material inventory counts.
• Confirm whether the first statutory audit agreement covers at least two years.
• Prepare the year-end closing and audit timetable.
• Align the local timetable with group reporting deadlines.
• Assign owners for inventory, fixed assets, revenue, provisions, tax and disclosures.
• Establish a central document repository.
• Review and update the accounting policy.
• Reconcile all material balance sheet accounts.
• Prepare and document significant estimates.
• Review impairment indicators.
• Prepare inventory count instructions and documentation.
• Inform the auditor of all material inventory locations and count dates.
• Reconcile local figures with the group reporting package.
• Confirm intercompany balances.
• Review events after the balance sheet date.
• Prepare the notes to the financial statements.
• Schedule the approval meeting.
• Plan the filing of the approved documents with the National Court Register.

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What should management do next?

A financial statement audit in Poland requires organisational preparation, not only accurate bookkeeping.

Management should determine the audit requirement early, appoint an authorised audit firm through the correct corporate procedure, sign the engagement agreement in time and provide the auditor with complete, reconciled information.

For foreign-owned companies, coordination between the Polish statutory audit and group reporting is equally important. A lack of alignment may lead to delays, additional adjustments and inconsistencies between the local financial statements and the figures reported to headquarters.

The most effective approach is to manage the audit as a structured project with:

• a documented timetable;
• clearly assigned responsibilities;
• one controlled document repository;
• early discussion of complex accounting matters;
• direct communication between local finance, management, the auditor and group headquarters.

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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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