Executive summary (30 seconds):
From 2025 mandatory audit thresholds rose by 25%. A company falling below the thresholds may terminate its auditor contract, but must notify PANA. The termination decision should be preceded by a business analysis — bank requirements, investor expectations or transaction plans may justify continuing on a voluntary basis. Companies approaching the thresholds should plan their first audit in advance.
From 2025 mandatory audit thresholds rose by 25%. A company falling below the thresholds may terminate its auditor contract, but must notify PANA. The termination decision should be preceded by a business analysis — bank requirements, investor expectations or transaction plans may justify continuing on a voluntary basis. Companies approaching the thresholds should plan their first audit in advance.
New thresholds in numbers
The mandatory audit applies to companies that met at least 2 of the 3 criteria below in the prior year:
Total assets
≥ EUR 3,125,000
approx. PLN 13.4m
Net revenues from sales
≥ EUR 6,250,000
approx. PLN 26.8m
Headcount
≥ 50 persons
average annual (FTE)
Thresholds are assessed against prior-year data. New thresholds apply to financial years commencing after 31 December 2024. EUR/PLN conversion uses the NBP rate from the last business day of the preceding financial year.
Example: A company with revenues of PLN 24m, total assets of PLN 11m and 45 employees — meets none of the 3 criteria. No mandatory audit for 2025.
🧮
Check your obligation in 30 seconds
Our audit threshold calculator checks your company automatically — it fetches the live EUR/PLN rate from NBP and compares the three Art. 64 thresholds against your data.
Open calculator →Terminate or stay — decision matrix
| Company situation | Recommendation | Rationale |
|---|---|---|
| Bank financing planned within 12 months | 🟢 Stay with auditor | Bank prefers or requires audited figures. Voluntary audit facilitates credit negotiations. |
| Share sale or M&A planned | 🟢 Stay with auditor | Audited historical financials reduce due diligence scope and support valuation. |
| Company approaching thresholds — will enter mandatory audit in 1–2 years | 🟡 Consider voluntary audit | Early audit will surface issues that would otherwise return under time pressure. |
| Stable company, no transaction plans, clearly below thresholds | 🔴 May terminate | No statutory obligation. Decision should be deliberate, not automatic. |
| Ownership change or new investor in the future | 🟢 Stay with auditor | A history of audited statements increases credibility in any transaction. |
Legal basis
The change follows an amendment to the Accounting Act and the Act on Statutory Auditors, Audit Firms and Public Oversight, effective from 1 January 2025. The 25% threshold increase implements an EU directive aimed at reducing administrative burden on smaller entities while maintaining standards for larger ones.
The new thresholds apply for the first time to financial years commencing after 31 December 2024 — for calendar-year companies, this is the year 2025.
How to terminate the auditor contract — step by step
- Resolution of the approving body — the shareholders' meeting or general assembly adopts a resolution to terminate the audit firm contract, citing the statutory threshold change as the reason.
- Written notice — the company sends written notice of termination to the audit firm.
- PANA notification — both the company and the audit firm must separately notify the Polish Audit Oversight Agency (PANA) of the termination. Failure to notify may result in sanctions.
- Documentation — retain documentation justifying the decision (financial data confirming non-fulfilment of the thresholds).
Important: If the company met the thresholds for 2024, the mandatory audit obligation for 2024 remains — regardless of the new thresholds. The new thresholds apply to 2024 data when assessing the obligation for 2025.
Mistakes when deciding to terminate
- Automatic termination without business analysis — the company dismisses the auditor because "it doesn't have to", then six months later applies for a bank loan and the bank asks for audited statements.
- Missing PANA notification — both the company and the auditor have a separate notification obligation. Omitting one side is a formal error.
- Incorrect threshold calculation — thresholds are assessed on prior-year data, not current. And the PLN conversion uses the NBP rate from the last business day of the preceding financial year, not the current rate.
- Terminating mid-audit — the contract may be terminated, but only after the engagement for a given year is complete. You cannot terminate a contract while the audit is in progress.
From my practice: I've seen companies automatically dismiss their auditor after the threshold change — without any business analysis. Three months later the owner decided to sell and the buyer required audited historical statements. Renegotiating the auditor contract took two weeks, and the absence of an audit history weakened the valuation. The decision to dismiss an auditor should be deliberate — not automatic.
FAQ
Frequently asked questions
Must I notify PANA when I terminate the auditor contract?▾
Yes. Both the company and the audit firm have a separate PANA notification obligation. This applies to every early termination, including termination due to failing to meet statutory thresholds.
When do the new thresholds apply for the first time?▾
For financial years commencing after 31 December 2024. For calendar-year companies: you assess 2024 data against the new thresholds to determine the audit obligation for 2025.
What if the company meets exactly 2 criteria?▾
Meeting exactly 2 criteria triggers the mandatory audit. Note that prior-year data may differ from current-year forecasts — it is worth rechecking every year.
Want to discuss how this topic applies to your company?
Book a short consultation with a statutory auditor and assess which risks or actions may apply to your situation.
Related articles
Read next
Related services