How to verify an audit firm in Poland?

To verify an audit firm in Poland before making an appointment, a company should review both the firm itself and the individual designated as the key statutory auditor. The firm should appear on the official list of audit firms, while the statutory auditor should be listed in the register maintained by the Polish Chamber of Statutory Auditors (PIBR). Companies should also examine penalties published by the Polish Agency for Audit Oversight (PANA), auditor independence, sector experience, access to specialists and the proposed organisation of the audit. Registration confirms that the firm is authorised to provide audit services, but it does not establish whether it is suitable for a particular company.

The importance of properly verifying an audit firm follows directly from the purpose of the audit. A financial statement audit in Poland is intended to provide reasonable assurance that the financial statements as a whole are free from material misstatement. The statutory auditor then expresses an opinion on whether the statements present a true and fair view of the entity’s financial position, financial performance and results. Audit quality, however, depends on more than the formal qualifications of the person signing the audit report.

For management boards and CFOs, sector knowledge, independence, team continuity, the ability to meet deadlines and the way significant findings are communicated are equally important.

The wrong choice may delay the approval of the financial statements, require the same data to be prepared repeatedly, create a backlog of questions at the end of the audit or force management to address issues that could have been identified much earlier.

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Does a company appoint an auditor or an audit firm in Poland?

In business discussions, companies usually refer to appointing an auditor or statutory auditor. From a legal perspective, however, the company appoints an audit firm and subsequently enters into an agreement with that firm for the audit of its financial statements.

The audit firm designates a key statutory auditor who has primary responsibility for the engagement. The statutory auditor who signs the audit report also has the status of a key statutory auditor.

This means that two levels should be examined before the appointment:

1. the audit firm as the contracting party and the entity responsible for the audit;
2. the key statutory auditor and the other members of the audit team.

The audit firm entering into the agreement is responsible to the audited entity. The reputation of an individual partner is therefore not sufficient if the company does not understand which entity will perform the engagement, who will be assigned to the team and how the audit will be organised.

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How can a company verify an auditor’s authorisation in Poland?

The initial verification should cover the official registers that are publicly available in Poland.

What should be checked?	Where should it be verified?	What should the company review?
Audit firm	Official list of audit firms	registration number, full legal name, address, legal form and current status
Key statutory auditor	PIBR register of statutory auditors	full name, registration number and current professional status
Auditor’s relationship with the firm	List of audit firms and PIBR register	whether the named individual is employed by or otherwise associated with the firm
Network membership	Information included in the list of audit firms	name of the network and associated entities
Administrative penalties	PANA list of penalties	nature of the infringement, date of the decision and penalty imposed
Civil liability insurance	Document provided by the bidder	insurance period and whether the coverage includes the planned audit activities

The list of audit firms includes, among other information, the registration number, company details, information concerning owners and governing bodies, the names of statutory auditors associated with the firm, branch addresses and information about network membership.

The register of statutory auditors is maintained by the National Council of Statutory Auditors. Individuals can be searched by surname, registration number or associated audit firm.

The current list of audit firms and a link to the register of statutory auditors are also made available by the Polish Agency for Audit Oversight (PANA).

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Is registration on the Polish list of audit firms sufficient?

No. Registration confirms that an entity is authorised to provide audit services in Poland, but it does not demonstrate that the firm has the experience and resources required to audit a particular company.

Formal verification is the first stage of the appointment process, not the final one. Two properly registered firms may differ significantly in terms of:

• experience in the relevant industry;
• the size and continuity of the audit team;
• access to tax and IT specialists;
• knowledge of International Financial Reporting Standards (IFRS);
• experience in auditing corporate groups;
• organisation of document and data exchange;
• availability of the partner responsible for the engagement.

Registration also provides no indication of what day-to-day cooperation will look like. A poorly organised audit generates not only the audit firm’s fee, but also additional internal costs for accounting, controlling, tax, IT and management teams.

From the audited company’s perspective, an effective audit should be transparent, predictable and proportionate to the actual risks. The client should know who is responsible for each area, what information must be prepared and when identified issues will be communicated.

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How can a company verify whether an audit firm has been penalised in Poland?

PANA publishes a list of administrative penalties imposed on audit firms. As a general rule, this information remains publicly available for five years after the relevant decision becomes final. The list describes the infringement and the penalty imposed. Where the infringement relates to a statutory audit, it may also indicate whether the audit report complied with statutory requirements.

A penalty should not be assessed without examining its context. An administrative omission should be evaluated differently from an infringement concerning auditor independence, the quality of audit documentation or the content of an audit report.

Companies should check:

• what the infringement specifically concerned;
• when it occurred;
• whether it was an isolated or systemic issue;
• what remedial measures the firm implemented;
• whether the penalty related to the quality of a particular audit.

It should also be remembered that the penalised firm is not identified in full in every published case. The absence of a firm’s name from the list should therefore not be treated as conclusive confirmation that the firm has never been subject to proceedings.

An audit firm may be penalised, among other reasons, for breaching independence requirements, failing to complete the required assessments before accepting an engagement, irregularities in an audit report, non-compliance with rotation rules or failure to maintain the required insurance.

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How should auditor independence be assessed in Poland?

An auditor should be independent of the audited entity both in fact and in the perception of an objective, informed third party.

The audit firm, members of the audit team and other persons who can influence the outcome of the audit must not participate in the audited entity’s decision-making. An audit should not be performed where financial, personal, business or employment relationships create an unacceptable threat to independence.

Before making an appointment, the company should ask the audit firm:

• whether it has previously provided accounting, tax, implementation or advisory services to the company;
• whether such services have been provided to other entities within the corporate group;
• whether any audit team members were previously employed by the audited company;
• whether personal or business relationships exist with management board members;
• which safeguards will be used to protect independence;
• whether entities belonging to the same network will participate in the engagement.

Before accepting or continuing an engagement, the audit firm and the key statutory auditor must assess and document compliance with the independence requirements. Audit team members submit the relevant declarations before the audit begins.

For international groups, the assessment should not be limited to the Polish company. Services provided by foreign entities belonging to the same network may also affect the independence assessment.

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How should a company evaluate an auditor’s industry experience?

Industry knowledge is not merely a matter of convenience for the client. It affects how risks are identified, how audit procedures are planned and how unusual transactions are assessed. The relevant areas will differ between manufacturing, real estate, retail, technology and international trading companies.

In a manufacturing company, the auditor should understand areas including:

• the calculation of production costs;
• the valuation of inventories and work in progress;
• the treatment of production variances;
• physical inventory procedures;
• impairment of machinery and inventories.

For an international group, relevant matters may include consolidation packages, differences between Polish accounting rules and group accounting policies, related-party transactions, foreign currencies and reporting deadlines imposed by the parent company.

Before making an appointment, the company should request information about:

• the number of audits completed in the relevant sector;
• the experience of the key statutory auditor;
• examples of typical risks identified in comparable entities;
• experience in auditing businesses of a similar size;
• familiarity with the accounting system used by the company;
• experience in group reporting.

A general statement that the firm understands the industry is not sufficient. A credible response should refer to specific processes, financial statement items and risks characteristic of the client’s operations.

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Does the entire audit team need to be assessed?

Yes. The partner or key statutory auditor does not perform every audit procedure personally. The quality and efficiency of the engagement depend on the entire team.

During the tender process, the company should establish:

• who will act as the key statutory auditor;
• who will manage the day-to-day audit work;
• how many people will be assigned to the team;
• what experience the team members have;
• whether the team composition is expected to remain stable;
• how much time the partner will devote to the engagement;
• who will make decisions on disputed or complex matters;
• who will replace key team members if they become unavailable.

Before accepting the engagement, the audit firm must assess whether it has competent staff, sufficient time and the other resources required to perform the audit properly.

Access to specialists is particularly important in areas that cannot be assessed reliably using standard accounting expertise alone. This may include valuations, taxation, IT systems, financial instruments, cybersecurity or sustainability reporting.

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How should the organisation and timetable of an audit in Poland be verified?

The organisation of the audit should be assessed during the tender process. The auditor should present not only the proposed fee, but also a clear delivery model.

The proposal should explain:

• when audit planning will begin;
• whether an interim audit is planned;
• when the auditor will attend the physical inventory count;
• when the list of required documents will be provided;
• how questions will be raised and tracked;
• when management will be informed of significant issues;
• the planned date for issuing the audit report.

The auditor should take account of the year-end closing calendar, group reporting deadlines, tax filings and the availability of management board members.

A timetable that does not reflect the company’s operational reality may result in most audit questions being raised during the busiest period for the finance department.

The company should also determine whether the proposed data exchange platform supports document version control, question tracking and secure access management. Technology should reduce repeated requests and manually prepared schedules. References to automation or artificial intelligence alone do not demonstrate that the audit process will be efficient.

A financial statement audit in Poland should be planned sufficiently early. HLB Poland can prepare an audit scope and timetable reflecting the scale of the company’s operations, its year-end closing deadlines and its group reporting obligations.

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Must an audit firm in Poland hold civil liability insurance?

Yes. An audit firm performing audit activities in Poland must hold civil liability insurance.

The insurance obligation arises no later than the day before the firm begins performing audit activities and continues until the firm is removed from the official list. Before entering into an agreement, the company may request current evidence of insurance. The verification should cover the insurance period and confirm whether the policy includes the activities covered by the proposed engagement.

Insurance does not replace a quality assessment of the firm, but it is one of the basic elements of formal due diligence.

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Who appoints an audit firm in a Polish company?

As a general rule, the audit firm is appointed by the body responsible for approving the financial statements, unless the articles of association, statutes or other binding regulations assign this authority to another body. The head of the entity, as defined under Polish accounting law, cannot make the appointment independently.

In a Polish limited liability company, the competent body will usually be the shareholders’ meeting, unless the articles of association assign this authority, for example, to the supervisory board. The management board may conduct a tender, collect information and negotiate the commercial terms. The formal appointment must nevertheless be made by the competent corporate body. The head of the entity then enters into the agreement with the selected audit firm.

The agreement should be signed sufficiently early to allow the auditor to attend the physical inventory count of significant assets. In the case of an initial agreement for a statutory audit, the engagement period cannot be shorter than two years.

Further information about the process is available in the article Audit in Poland: a step-by-step financial statement audit guide.

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What additional auditor checks apply to public-interest entities in Poland?

Public-interest entities, including selected financial market entities and securities issuers, are subject to additional requirements concerning auditor appointment, independence and rotation.

In such cases, the company should verify:

• whether the firm performs audits of public-interest entities;
• whether the appointment complies with the entity’s internal policy and procedure;
• the recommendation issued by the audit committee;
• the scope of non-audit services;
• the length of the existing relationship with the firm and the key statutory auditor;
• compliance with mandatory rotation requirements.

The standard maximum period for which a public-interest entity may continuously engage the same audit firm is ten years. A longer period is possible only in the circumstances specified in Article 17 of Regulation (EU) No 537/2014.

The key statutory auditor may not perform the statutory audit of the same entity for more than five years. The individual may participate in the audit again only after a cooling-off period of at least three years.

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What questions should a company ask an auditor before appointment?

Before submitting a recommendation to the corporate body responsible for the appointment, the company should obtain answers to the following questions:

1. What is the firm’s registration number on the official list of audit firms?
2. Who will act as the key statutory auditor?
3. What experience does the proposed team have in our industry?
4. How many comparable audits has the team completed in recent years?
5. Has the firm or its network provided any services to our group?
6. How will the firm confirm and protect its independence?
7. How large will the team be, and what will the partner’s role involve?
8. Does the firm have access to tax, IT and valuation specialists?
9. What is the proposed timetable, and when will the document request list be provided?
10. How will questions be raised, assigned and monitored?
11. What is included in the quoted fee?
12. Which circumstances may result in additional fees?
13. Does the firm hold current civil liability insurance?
14. How will audit documentation and company data be protected and stored?
15. When will management be informed of significant irregularities or control issues?

The answers should be documented in a tender evaluation sheet. This allows the company to compare candidates using consistent criteria and provides a documented basis for the recommendation made to the appointing body.

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How should a statutory auditor in Poland be verified? Summary

The process should begin by checking the audit firm on the official Polish list and verifying the key statutory auditor in the PIBR register. The company should then assess independence, industry experience, team composition, available resources, the proposed timetable and the commercial terms.

The assessment should combine three perspectives:

• formal verification – authorisation, registers, penalties and insurance;
• technical verification – sector experience and access to specialists;
• operational verification – timetable, communication and organisation of data exchange.

Only this combined assessment can establish whether a firm is not only formally authorised to conduct a financial statement audit in Poland, but can also complete the engagement on time, independently and without placing an unnecessary burden on the organisation.

Companies looking for an audit firm can review the scope of HLB Poland’s financial statement audit services. Discussing the business structure, reporting deadlines and key risks at an early stage allows the audit scope and timetable to be defined appropriately.

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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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