A Polish subsidiary of a foreign group typically has two audit obligations: a statutory audit under Polish GAAP (UoR) filed with the National Court Register, and an IFRS or group-GAAP consolidation package submitted to the parent. These are separate engagements with different standards, deadlines and purposes — but they can be managed by a single auditor.
Two separate obligations
Foreign investors setting up or acquiring a Polish subsidiary are sometimes surprised to learn that their Polish entity has two distinct reporting obligations that may each require an auditor:
- Statutory audit under the Polish Accounting Act (UoR): Required by Polish law once the entity exceeds the size thresholds in Article 64 UoR. The auditor issues a statutory audit report and opinion. Financial statements are filed with the National Court Register (KRS).
- IFRS consolidation package review: Required by the parent group for consolidation purposes. The package is prepared under IFRS, US GAAP or the group's own accounting policies — not Polish GAAP. The auditor reviews or agrees procedures on this package and reports to the group auditor.
The two obligations can exist independently. A subsidiary may require only the statutory audit (if the parent does not require a package), or both (more common in practice).
Statutory audit thresholds (Article 64 UoR)
A Polish entity is required to have its financial statements audited if, in the preceding financial year, it met at least two of the following three thresholds:
| Threshold | Value |
|---|---|
| Balance sheet total | PLN 2,500,000 (approx. EUR 550,000) |
| Net revenue from sales | PLN 5,000,000 (approx. EUR 1,100,000) |
| Average annual headcount | 50 full-time equivalents |
UoR audit vs IFRS consolidation package: key differences
| Dimension | Statutory audit (UoR) | IFRS consolidation package |
|---|---|---|
| Legal basis | Polish Accounting Act + KSB (Polish audit standards) | IFRS / group accounting policies + ISA / group audit instructions |
| Financial statements | Polish GAAP financial statements | IFRS-based reporting package |
| Addressee | Shareholders, KRS, creditors | Parent company / group auditor |
| Deadline | Statutory deadline (before approval of financial statements) | Group reporting calendar (typically earlier) |
| Output | Statutory auditor's report and opinion | Component auditor memorandum / agreed procedures report |
Component auditor role (ISA 600)
When the group auditor issues an opinion on consolidated financial statements, they rely on work performed by component auditors — the local auditors of individual subsidiaries. This relationship is governed by ISA 600 (Standard on the Audit of Group Financial Statements) and its Polish equivalent KSB 600.
The component auditor (JMFC, as the Polish auditor) must:
- Confirm independence and professional qualifications to the group auditor
- Execute audit procedures specified in the group audit instructions
- Report findings in the format required by the group auditor
- Respond to queries and review requests from the group auditor within the group reporting calendar
One auditor for both engagements
There is no legal requirement to use the same auditor for the statutory audit and the IFRS package review — but doing so has practical advantages:
- Single planning process: The auditor understands both the UoR and IFRS positions of the entity and can identify differences (IFRS adjustments) efficiently.
- Reduced client overhead: One set of fieldwork, one PBC list, one primary contact — rather than coordinating two separate audit teams.
- Better coordination with the group auditor: A single component auditor provides one consolidated set of findings and one point of contact for the group audit team.
- Faster delivery: Work performed for the statutory audit (e.g. substantive testing of balance sheet items) is typically reusable for the IFRS package review.
For Warsaw-based subsidiaries, see also: financial audit Warsaw and IFRS consolidation services.
Frequently asked questions
Managing a Polish subsidiary's audit obligations?
JMFC handles both the statutory UoR audit and IFRS consolidation packages for Polish subsidiaries of foreign groups — coordinating directly with the group auditor under ISA 600.