Every year the Committee of European Auditing Oversight Bodies (CEAOB) collects data from the member states on the sanctions imposed on statutory auditors and audit firms. The countries report them in a single questionnaire, which makes it possible to compare Poland with the other countries of the European Union and the European Economic Area (EEA).
We analysed the questionnaires for 2021–2025. Below we describe three findings: Poland’s share of one category of sanctions, the absence of a certain group of measures from the Polish data, and the change that took place over this period in the public-interest entity (PIE) segment.
Category A.5
The questionnaire distinguishes categories of sanctions. One of them is A.5: a declaration that the audit report does not meet the requirements. The strongest finding of the analysis concerns precisely this category. Poland accounts for 53–79% of all such sanctions across the EU and EEA and has ranked first in each of the five years. The country in second place did not exceed 16% in any year.
Source: CEAOB sanctions questionnaires for 2021–2025, compiled by the Ad Legem Foundation. In 2022 Iceland did not report data in category A.5.
The chart shows how many A.5 sanctions were imposed in Poland in each year and how many in all the other EU and EEA countries combined. Poland’s share is given above each bar. Poland imposed 23 of 29 sanctions in 2021, 41 of 63 in 2022, 51 of 95 in 2023, 41 of 78 in 2024 and 41 of 74 in 2025. In each of these years Poland imposed more A.5 sanctions than all the other countries together. Poland’s share fell from 79% in 2021 to 65% a year later and has been in the 53–55% range since 2023.
Missing measures and a shrinking segment
What the data do not contain is just as important. The CEAOB questionnaire has a separate section for measures outside the catalogue of sanctions, that is, graduated responses below the threshold of a formal sanction. Other countries make wide use of it. In five years Poland has not reported a single measure there.
The shrinking market adds to this picture. The number of firms auditing public-interest entities fell from 67 in 2021 to 48 in 2025, a decrease of 28.4%. In this segment the intensity of sanctions, measured as the number of sanctions per 10 firms, rose from 1.34 to 6.67. In 2025 it was 3.64 times the European average.
A model of response
Nothing in these data suggests that Polish auditors audit any worse than their German or Czech counterparts. The difference lies rather in the model of response: where others start with recommendations and a remediation plan, the Polish system goes straight to a sanction. We are presenting the conclusions of the analysis to the CEAOB and the European Commission.
This sequence — first a recommendation, and only then a sanction — is what the foundation proposes in area III of its proposals, which is devoted to a proportionate response.