Poland: Biegli Rewidenci CPD, 120 Hours and a New ESG Cycle

Poland’s CPD regime for statutory auditors is one of the more tightly engineered in Europe, and it is about to become two regimes rather than one. The current requirement is 120 lesson hours over three calendar years. From 1 January 2027, auditors authorised for sustainability-reporting assurance are proposed to carry a second, separate 24-hour cycle on top — 144 hours in total, administered as two independent settlement accounts.

Who writes the rules, and who switches them on

Two bodies, and the division matters. The Polska Izba Biegłych Rewidentów (PIBR) — the Polish Chamber of Statutory Auditors — sets the numbers through its national council, the Krajowa Rada Biegłych Rewidentów (KRBR). But each resolution takes legal effect only once the Polska Agencja Nadzoru Audytowego (PANA), the Polish Audit Oversight Agency, approves it.

So PIBR writes the hours and PANA switches them on. That is why the draft 2027 resolutions discussed below are not yet law: they are published, consulted on, and awaiting approval.

The instruments

• Ustawa z dnia 11 maja 2017 r. o biegłych rewidentach, firmach audytorskich oraz nadzorze publicznym — the Act of 11 May 2017, Dz.U. 2017 poz. 1089. Article 9 carries the obligation, the self-study rules, documentation and retention. Article 10(11)(2) is the enabling power under which the council sets the settlement period and the minimum hours.
• Rozporządzenie Ministra Rozwoju i Finansów z dnia 15 grudnia 2017 r. on obligatory professional development, Dz.U. 2017 poz. 2391 — the procedural regulation. It governs what counts as training and what providers must report, and contains no hours figure, expressly leaving hours to the council.
• Uchwała Nr 205/7a/2023 KRBR of 7 December 2023 — the operative instrument setting the current hours and cycle.

The term of art is obligatoryjne doskonalenie zawodowe (ODZ), obligatory professional development. A godzina lekcyjna — lesson hour — is 45 minutes, which matters when comparing Poland to regimes counting clock hours.

The current numbers, from 1 January 2024

• 120 lesson hours over three consecutive calendar years.
• At least 72 of those hours must be delivered by PIBR or an jednostka uprawniona — an entitled training unit.
• At least 24 hours per calendar year, from an entitled unit.
• Self-study is capped at 48 hours per cycle.
• No carry-forward. Excess hours do not roll into the next period.
• Auditors entered on the register mid-cycle: 40 hours per year, split 24 required training and 16 self-study, completable in any year of the period but no later than its end.

One detail worth drawing out: there is no distinction between practising and non-practising auditors. The provision applies identically to a biegły rewident wykonujący zawód and one niewykonujący zawodu. The Act actually permits the council to differentiate, and the council has chosen not to. Several European regimes do reduce the load for non-practising members — Romania halves it — so this is a deliberate Polish choice rather than an oversight.

There is no ethics hours quota. The 2026 topic guidelines devote two modules of four hours each to the IESBA Code, but that is programme content on offer, not a floor.

Records: three years, and thirty days to produce them

Documentation must be kept for three years from the end of the calendar year in which the CPD was completed, and produced within 30 days of a council request.

If an auditor misses the deadline, the council may — on a documented and justified request — allow completion up to two years after the original date. That is an unusually long grace mechanism by European standards.

No routine annual filing — the burden sits with providers

This is the structural feature that distinguishes Poland. There is no routine annual CPD filing date for auditors. Documentation is produced on request. Instead the reporting burden falls on training providers: entitled units must notify PIBR of dates, locations and topics at least 30 days before a course starts, submit attendee lists within 10 days of an in-person course, and within 7 days after month-end for e-learning.

Compare Czechia, which excuses an auditor from filing entirely if all hours came through the chamber, or Portugal’s accountancy body, where a missed filing deadline brings an automatic bar on practising. Enforcement design varies across Europe considerably more than the hours do.

A caution for anyone researching the self-study rules: a 2018 council communication sets out the declaration contents — name and register number, form of self-study, dates, hours, subject matter and a justification of how it updated knowledge — and refers to a ratio that reflects the pre-2024 cycle structure. We are not reproducing that ratio, because it may have been superseded by the 2023 resolution. Check a current PIBR communication before relying on any self-study proportion.

The 2027 split: two cycles, 144 hours

Poland has run a public consultation on dividing CPD into two parallel cycles from 1 January 2027, through two draft council resolutions.

The mainstream cycle (ODZ Finansowy) keeps the headline numbers unchanged — 120 lesson hours over three years, at least 72 from PIBR or entitled units, at least 24 per calendar year, up to 48 self-study. What the resolution does is re-base the cycle to start on 1 January 2027. The 2023 resolution remains in force to 31 December 2026 and is repealed when the new one is approved.

The new ESG cycle (ODZ ESG) is a genuinely separate obligation for biegły rewident authorised for sustainability-reporting assurance, whether or not they practise:

• Three-year settlement period from 1 January 2027
• Minimum 24 lesson hours per cycle
• At least 8 hours from PIBR or another body authorised to deliver sustainability-assurance training
• Up to 16 hours self-study, counting toward the 24
• A reduced requirement for auditors acquiring the entitlement mid-cycle

So from 2027 an ESG-authorised Polish auditor faces 120 + 24 = 144 lesson hours per three-year cycle, tracked as two separate accounts rather than one pooled total.

Both remain drafts. The resolution numbers and dates are still placeholders in the published texts, and neither had been approved by the oversight agency at the time of writing. Treat the 144-hour figure as a well-documented proposal, not a requirement, and check approval status before planning against it.

Poland’s approach is at one end of a wide European spread on sustainability CPD: Austria added 40 hours over three years with a 10-hour annual floor, Romania 6 hours a year, Greece a one-off 30-hour seminar block for existing licensees, and Czechia nothing at all.

A note on the topic guidelines

PIBR publishes annual topic guidelines as separate resolutions, and the 2026 module list sums to a large number of available content hours. That is a menu, not a requirement. It is occasionally quoted as though it were the obligation, and it is not — the requirement is the 120 hours in the council resolution.

Who this applies to

The regime covers biegły rewident only. We did not establish whether Polish general accountants carry any equivalent statutory obligation, and we are not going to assert one either way — bookkeeping services in Poland were deregulated and the main accountants’ association is voluntary, but we verified neither at source.

That pattern is consistent across Europe: the quantified obligation attaches to the statutory audit perimeter, because that is what the EU Statutory Audit Directive reaches. And like most of its neighbours, Poland landed on 120 hours over three years — a figure we trace in our guide to why European CPD keeps converging on that number.

Frequently asked questions

How many CPD hours does a Polish statutory auditor need? 120 lesson hours over three consecutive calendar years, with at least 72 from the chamber or an entitled unit and at least 24 in each calendar year.

How long is a lesson hour? 45 minutes.

Can I carry hours forward? No. Excess hours do not roll into the next period.

Is there an annual return? No routine filing date. Documentation is produced within 30 days of a request, and training providers report attendance to the chamber.

What changes in 2027? Two draft resolutions would re-base the main cycle and add a separate 24-hour ESG cycle for sustainability-authorised auditors, giving them 144 hours per cycle. Both still require oversight-agency approval.

Train with a provider that satisfies the delivery rules

Poland is one of the regimes where who delivers the training decides whether it counts: 72 of the 120 hours must come from the chamber or an entitled unit, and self-study is hard-capped. Our certificated CPD courses are built to be evidenced against exactly that kind of rule. Compare the French approach in our guide to commissaires aux comptes CPD. The Act of 11 May 2017 is published by the Sejm.