POLAND Trends and Developments Contributed by: Michał Mostowik, Karol Juraszczyk, Kamila Mróz and Jakub Lach, Deloitte Legal, Gizicki i Wspólnicy sp.k.
due to report in 2026 and 2027, and to postpone the transposition deadline and the first wave of application of the CSDDD by one year to 2028. Because of the encompassing nature of the changes, which need to be agreed upon and (in many cases) transposed into national law, as well as additional works in the pipeline (ie, those included in the European Commission Work Pro - gramme for 2025), while the overall direction of the changes has been met with cautious approv - al from parts of the market, the general senti - ment remains one of increased awareness about the inherent uncertainty of the processes ahead. Notwithstanding the above, it seems that the EU continues its transformation programme (although adjusted), finding new ways to tackle greenwashing and foster changes. Non-Obvious Interplay of Digital Transformation, ESG Reporting and Carbon Footprint Managing a carbon footprint, understood as the total greenhouse gases emitted, is an over -
arching concept of the ESG Regulations. How it affects the digital economy has previously been tackled from different angles, both looking at the possible impact of the overall “sustainable digital footprint” (that is including environmen - tal, social and business aspects and trying to quantify them) and the carbon footprint in par - ticular, focusing on the “digital carbon footprint” (the carbon footprint of the digital services and the hardware necessary to sustain them across the value chain). Recent developments and an increasing con - cern for Polish fintechs (which by definition are reliant on digital services) is having an impact on the possible redundancy or inefficiencies intro - duced in the process of achieving compliance with the ESG Regulations, mainly in the area of data gathering and processing. As the regula - tory ESG landscape and reporting obligations in particular are rapidly evolving, this issue needs careful monitoring both in terms of assessment of the existing framework and the potential impact of the changes introduced during ongo - ing and future alignment processes.
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