Accounting / SME management

Accounting policy after entity category change 2025 — what to update

New Polish Accounting Act thresholds from 2025 mean some companies changed category — from small to medium or the other way around. A change of category has concrete consequences for accounting policy and financial reporting obligations.

29.04.20265 min readAccounting / Polish GAAP / SME
01
A category change alters the available simplifications and mandatory financial statement components.
02
A company that became a small entity may now drop the cash flow statement and statement of changes in equity.
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Failure to update accounting policy after a category change is an error an auditor will find.
Summary (30 seconds):
The 2025 Accounting Act amendment raised entity size thresholds. Some companies changed category — which directly affects reporting obligations and available simplifications. A company that became a small entity may drop the cash flow statement and statement of changes in equity. A company that became large has new obligations. Accounting policy must reflect the current category — failure to update is a formal error.

Check your entity category

CategoryTotal assetsNet revenuesHeadcount
Micro≤ EUR 1.5m≤ EUR 3m≤ 10 persons
Small≤ EUR 7.5m≤ EUR 15m≤ 50 persons
Medium≤ EUR 25m≤ EUR 50m≤ 250 persons
Large> EUR 25m or> EUR 50m or> 250 persons

Thresholds converted to PLN at the NBP rate. Category determined on prior-year data — meeting at least 2 of the 3 criteria above the "small" threshold means the next higher category applies.

What a category change means

Financial statement componentMicro/SmallMedium/Large
Cash flow statementOptionalMandatory
Statement of changes in equityOptionalMandatory
Management commentarySimplified or noneFull
Deferred income taxOptional (small)Mandatory
Financial instrument measurementSimplifiedFull effective interest method
Note disclosuresLimitedFull

Simplifications for small entities — what you can gain

If your company became a small entity under the new 2025 thresholds — you may use several simplifications that must be recorded in accounting policy:

  • No cash flow statement — saves time at year-end close
  • No statement of changes in equity — simplified reporting
  • Simplified financial instrument measurement — at nominal value instead of effective interest rate
  • No deferred income tax — if not material for a faithful presentation
  • Simplified notes — fewer mandatory disclosures
Important: Using a simplification requires a formal decision by the approving body (shareholders' meeting) and recording it in accounting policy. Simply not meeting the thresholds is not enough — the decision must be formalised.

Accounting policy errors after a category change

  • No policy update — the company changed category but accounting policy still references the old category and old simplifications.
  • Using simplifications without a formal resolution — the company simply does not prepare a cash flow statement without documenting this decision in the policy and a board resolution.
  • Notes not aligned with the new category — the company became a large entity but notes are at the level of a small entity.
  • No annual reviewaccounting policy should be reviewed every year or at every material change.
From my practice: The most common error is an accounting policy drafted when the company was incorporated and never updated. After 5–10 years of growth the company has a completely different scale and category, but documents its accounting using micro-entity rules. Auditors ask about every discrepancy between policy and practice.

Frequently asked questions

Must I check my entity category every year?
Yes. Entity category is determined every year on prior-year data. For a rapidly growing company it may change every 2–3 years.
Does a change in accounting policy require retrospective restatement of historical data?
Depends on the type of change. A category-related change (e.g. adding a cash flow statement) does not require restatement of historical data. A change in measurement policy (e.g. from cost to fair value) typically requires retrospective recognition.

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