Nearshoring from Poland: ESG supplier requirements under CSRD and LkSG (2026)

If you supply goods or services from Poland to German industrial customers, your customer may ask for ESG data even when the law does not cover your company directly. After the 2026 changes, the legal requirements for most suppliers are lighter than expected, but customer questions have not gone away. The best response is one consistent evidence pack rather than a fresh answer to every questionnaire.

Reading time: 8 min · Strategy · Legal position as of 26 October 2026 · Commplace® since 1996

You are reading the English version. We cover this topic separately in Polish and in German.

ESG requirements for Polish suppliers: why German customers ask

Large German industrial and manufacturing companies report on sustainability and answer for their supply chain. To do that, they ask suppliers for data: emissions, working conditions, certificates, how subcontractors are handled. This applies to Polish firms in nearshoring too, meaning production or services moved close to the target market.

One distinction matters: a rule that binds your customer does not automatically bind you. The customer asks because it has to collect the data itself. So it pays to know what the law requires and what is only purchasing practice, where you can negotiate a reasonable scope.

In conversations with industrial companies we see more enquiries about communication in this area. That is an observation, not a market measurement: we have no study confirming it, so treat it as a hypothesis to test with your own customers.

CSRD after the 2026 changes: who is covered

CSRD is the EU directive on sustainability reporting. The simplification package known as Omnibus I was adopted by the Council on 24 February 2026 and entered into force on 18 March 2026. The most important change is a much higher threshold.

Reporting companies are now those with more than 1,000 employees and more than 450 million euros of net turnover at the same time. First reports are due in 2028, for financial years starting on or after 1 January 2027. For many companies that had been preparing, the obligation has fallen away.

For Polish suppliers one more provision is key: the so-called value-chain cap. A reporting company may not ask a partner with fewer than 1,000 employees for information beyond the voluntary reporting standard. For small and medium-sized companies that is the VSME standard developed by EFRAG. In practice: if you have fewer than 1,000 people, your customer has limited grounds to demand more from you.

LkSG and CSDDD: what applies and what is only planned

The LkSG is the German supply chain due diligence act. It applies to companies with 1,000 or more employees in Germany. Duties on risk management, risk analysis and remedial measures remain in force, as does the documentation duty with seven-year retention.

What changed in practice is that the supervisory authority, BAFA, has not checked annual reports since November 2025 and pursues only serious violations. A draft law would formally remove the reporting duty. According to an analysis from September 2026 this has not yet been adopted, and the governing coalition has announced it will raise the threshold to 5,000 employees. Treat this as a position to confirm before you base reports or contracts on it, because the German rules keep changing.

The German act is ultimately meant to be replaced by a law implementing the EU directive CSDDD. After the changes that directive covers companies with more than 5,000 employees and 1.5 billion euros of turnover, and Member States must transpose it by 26 July 2028. The requirement to adopt climate transition plans and the EU-wide civil liability regime were removed, and maximum fines are capped at 3 percent of worldwide turnover.

Conclusion for suppliers: the law demands less than a year ago, but large customers still assess supply chain risk. The difference is that you can discuss scope instead of just filling in forms.

Supplier evidence pack: prepare once, use many times

Instead of answering each request separately, prepare a standing pack. It lets you respond quickly and consistently, and the customer sees an orderly, predictable company. That matters in Germany, where buyers generally value documentation and rigour.

• Company profile: headcount, turnover, locations, main products and services. It shows at once whether the rules cover you at all.
• Supplier code of conduct: a short document on working conditions, safety and treatment of subcontractors, signed by management.
• Certificates and confirmations you actually hold, for example environmental and occupational safety management systems.
• Basic environmental data: energy use and, if you measure it, emissions. Report only what you can document.
• A description of your own supply chain: key suppliers and how you check their reliability.
• A named person responsible for ESG matters and a contact address for customers.

To go a step further, consider a short report under the voluntary standard for small and medium-sized companies. It answers most typical customer questions in one familiar form.

B2B ESG communication: how to show it to a German buyer

Evidence is half the job. The other half is how you present it. One well-made page for German customers, in German, with a downloadable pack and a named contact, often does more than an elaborate campaign.

Avoid general phrases such as „we care about the environment” or „we are a responsible partner”. An industrial buyer looks for numbers, dates, certificate names and an answer to what happens when something goes wrong. Write specifically and do not promise more than you can prove. Exaggerated environmental claims damage credibility and carry legal risk.

It also helps to have a spokesperson who can answer in German, and a short expert article for trade media. What to translate and what to write from scratch is covered in our article on localising communication for foreign markets (Polish), and the first months in the German market in entering the German market (Polish).

For industrial companies we also recommend PR for manufacturing companies (Polish) and our page on a marketing agency for the German market (Polish).

How to measure whether it works

A good measure is not page views. Check how many ESG questionnaires you closed using the ready pack, how long a typical request takes to answer, and whether the customer asks fewer follow-up questions. Record the starting point today and assess after one quarter.

Remember: coincidence is not impact. If enquiries from Germany rise after you publish the page, ask customers whether it helped and compare with the period before. Treat conclusions from a single quarter as preliminary.

How Commplace works on ESG communication for exporters

We work like a doctor: diagnosis, tests, plan, implementation, check-up. First we find out what questions your customers really ask and what you can already prove. Then we build the message and the evidence pack, and finally measure whether questionnaires are answered faster and more consistently. Our offer is described on the communication strategy page (Polish).

What we do not do: we are neither a law firm nor an auditor and we do not issue statements of compliance. Legal text and certification belong to specialists. We help organise what the company already has and convey it so that a buyer in Germany understands it. Quote after a short conversation.

Source: Commplace® editorial team. This text is for information only and is not legal advice or a guarantee of results. Consult a lawyer before legal decisions.