Accounting market study

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PROJECT FINANCED BY THE SWISS CONTRIBUTION TO THE ENLARGED
EUROPEAN UNION

This report was prepared within the framework of Financial Reporting
Technical Assistance Program (FRTAP)

Date: September 2013


CONTENTS
LIST OF ACRONYMS .......................................................................................................... v
ACKNOWLEDGEMENTS .................................................................................................... vi
EXECUTIVE SUMMARY ...................................................................................................... 1
Financial Reporting Technical Assistance Program ............................................................. 1
The Study ............................................................................................................................. 1
Structure and content of the report .................................................................................... 2
Key Findings ......................................................................................................................... 4
CONCLUSIONS AND RECOMMENDATIONS ........................................................................ 8
Eliminating information gaps ............................................................................................... 8
Companies offering accounting and book-keeping services ............................................... 9
Analysis of employment in the breakdown according to accounting professions in the
entire economy .................................................................................................................. 10
Impact of the SME sector on labour market for accountants ........................................... 12
FOREWORD .................................................................................................................... 14
1. INTRODUCTION ........................................................................................................ 18
1.1. Objective and scope of research .............................................................................. 18

1.2. A&A market stakeholders ........................................................................................ 21
1.2.1. Ministries ..................................................................................................... 21
1.2.2. Professional self-government ..................................................................... 23
1.2.3. Professional organizations .......................................................................... 23
1.2.4. Oversight bodies .......................................................................................... 24
1.2.5. Training institutions/companies and pedagogical supervision ................... 25
1.2.6. Industry organizations and business support/business environment
institutions ................................................................................................... 25
1.2.7. Enterprises (including accounting and auditing firms) ............................... 26
1.2.8. Accountants and auditors ........................................................................... 27
1.3. Research methods .................................................................................................... 27
2. ACCOUNTING RELATED PROFESSIONS ....................................................................... 31
2.1. Law and other regulations pertaining to accountant profession ............................ 31
2.2. Overview of classification of accounting/auditing professions ............................... 34
2.3. Professions regulated by the law ............................................................................. 40
2.3.1. Introduction ................................................................................................. 40
2.3.2. Statutory auditor – formal and legal requirements .................................... 41
2.3.3. Tax advisor – principles of practicing the profession .................................. 49
i


2.3.4. Obtaining certification for providing bookkeeping services ....................... 55
2.3.5. Regulated professions in public finance sector entities ............................. 60
2.3.6. Principles of recognizing qualifications of EU member states citizens in
scope of regulated professions ................................................................... 66
2.4. Other professions on A&A market ........................................................................... 70
2.4.1. Professions with professional qualifications standards .............................. 70
2.4.2. Teachers and academic teachers in accounting specializations ................. 78
2.4.3. Other professions ........................................................................................ 85
2.5. Profession of an accountant in legal regulations of selected EU countries ............. 97

2.6. Conclusions............................................................................................................. 106
3. EDUCATION PATHS OF ACCOUNTANT PROFESSION ................................................. 110
3.1.
3.2.
3.3.
3.4.

Introductory information ....................................................................................... 110
Secondary and post-secondary education ............................................................. 111
Tertiary education .................................................................................................. 118
Principles and role of professional certification .................................................... 124
3.4.1. SKwP certification ...................................................................................... 124
3.4.2. ACCA certification ...................................................................................... 137
3.4.3. CIMA certification ...................................................................................... 141
3.4.4. Other qualifications ................................................................................... 145
3.5. Conclusions............................................................................................................. 148
4. LABOR MARKET FOR A&A PROFESSIONS ................................................................. 151
4.1. Quantitative analysis of entities that provide accounting services ....................... 151
4.2. Employment analysis in the breakdown according to occupational groups in light
of Central Statistical Office (GUS) data .................................................................. 162
4.3. Impact of the SME sector on labor market for accountants .................................. 168
4.4. Quantitative and qualitative analysis of regulated professions ............................ 183
4.4.1. Statutory auditors ..................................................................................... 183
4.4.2. Tax advisors ............................................................................................... 193
4.4.3. Individuals with an accountant certificate ................................................ 199
4.4.4. Chief accountants and internal auditors in public finance sector entities
(PFSEs) ....................................................................................................... 207
4.5. Outsourcing of book-keeping and accounting services ......................................... 214
4.5.1. Outsourcing status .................................................................................... 214
4.5.2. Accountancy firms ..................................................................................... 217

4.5.3. Outsourcing centers .................................................................................. 218
4.6. Compensation ........................................................................................................ 228
4.7. Unemployment ...................................................................................................... 241
4.8. Conclusions............................................................................................................. 256
5. NEW TRENDS AND DIRECTIONS OF CHANGES PLANNED FOR THE A&A PROFESSIONS
MARKET.................................................................................................................. 261
5.1. The A&A Professions Market vs. State Policy Directions ....................................... 261
5.2. Impact of Deregulating Legislation on Regulated A&A Professions ...................... 270
ii


5.2.1. Deregulation: Stage One ........................................................................... 272
5.2.2. Deregulation: Stage Two ........................................................................... 272
5.2.3. Deregulating the Statutory Auditors Profession ....................................... 273
5.2.4. Deregulating the Tax Advisors Profession ................................................. 276
5.2.5. Deregulation of bookkeeping services ...................................................... 279
5.2.6. III tranche of deregulation ......................................................................... 281
5.3. New types of accounting services .......................................................................... 282
5.4. New trends in education of accountants ............................................................... 291
5.5. Conclusions............................................................................................................. 301
6. SCOPE OF DATA COLLECTED BY STAKEHOLDERS ...................................................... 302
6.1. Background information ........................................................................................ 302
6.2. Data collected by GUS (Polish Central Statistical Office) ....................................... 302
6.2.1. Public statistics resources from the standpoint of A&A market ............... 302
6.2.2. The unemployed and job seekers registered in labor offices ................... 313
6.2.3. Job vacancies ............................................................................................. 318
6.2.4. Work permits for foreigners in Poland...................................................... 322
6.2.5. Compensation structure............................................................................ 323
6.2.6. Employment and compensation in public administration and national
defense, mandatory social security and universal health insurance ........ 324

6.2.7. Primary schools, junior high schools and schools above junior high
level ........................................................................................................... 328
6.2.8. Tertiary education facilities and their financial situation ......................... 330
6.2.9. Choice of educational paths versus career status of young Poles ............ 333
6.2.10. Education of adults .................................................................................... 334
6.2.11. Human Resources for Science and Technology (HRST) ............................. 335
6.2.12. REGON register .......................................................................................... 336
6.2.13. Other resources ......................................................................................... 341
6.3. Data collected by other stakeholders .................................................................... 342
6.3.1. Ministries ................................................................................................... 342
6.3.2. Professional self-governing organizations ................................................ 347
6.3.3. Associating and professional organizations .............................................. 349
6.3.4. Supervisory authorities ............................................................................. 351
6.3.5. Industry and support organizations/business environment institutions .. 354
6.3.6. Other.......................................................................................................... 355
6.4. Conclusions............................................................................................................. 362
7. FINAL COMMENTS .................................................................................................. 365
8. SUMMARY .............................................................................................................. 368
8.1.
8.2.
8.3.
8.4.

Objective and subject of the study ........................................................................ 368
Research methods .................................................................................................. 370
Content of the report ............................................................................................. 370
Main findings .......................................................................................................... 372

iii

8.4.1. Conclusions in scope of definition of an accountant and the accountant
profession (Section 2 of the Report) ......................................................... 372
8.4.2. Conclusions in scope of education of accountants (Section 3) ................. 373
8.4.3. Conclusions in scope of A&A labor market analysis (Section 4 of the
report) ....................................................................................................... 374
8.4.4. Conclusions in scope of directions of changes in the A&A market (Section
5) ................................................................................................................ 376
8.5. Identification of gaps in collected data .................................................................. 377
8.6. Recommendations ................................................................................................. 378
LIST OF TABLES ............................................................................................................. 379
LIST OF GRAPHS............................................................................................................ 382
LIST OF FIGURES ........................................................................................................... 386
LIST OF ATTACHMENTS ................................................................................................. 387

iv


LIST OF ACRONYMS
A&A
A&F
ABSL
ACCA
AoA
AoPS
AoES
AoTEL
AOC
AoPF
AoSA

AoTA
BDL
BPO
CEIDG
CIMA
CPS
CRP KEP
GUS
IFAC
IIA
KIBR
KNF
KRBR
KRDP
KRK
KRS
MLSP
MoF
MSaHE
PAIiIZ
PARP
PFSE
PKA
PKD
RIO
SKwP
SME
SSC
TSGU

Accounting and Auditing
Accounting and Finance
Association of Business Service Leaders
The Association of Chartered Certified Accountants
Act on Accounting
Act on Public Statistics
Act on Education System
Act on Tertiary Educaton Law
Audit Oversight Commission
Act on Public Finance
Act on Statutory Auditors
Act on Tax Advisory Services
Bank of Local Data
Business Process Outsourcing
Central Register and Information about Economic Activity
The Chartered Institute of Management Accountants
Classificaton of professions and specializations
Central Register of Entities in National Register of Taxpayers
Central Statistical Office
International Federation of Accountants
The Institute of Internal Auditors
National Chamber of Statutory Auditors
Finacial Supervision Authority
National Council of Statutory Auditors
National Council of Tax Advisors
National Qualification Framework
National Court Register
Ministry of Labor and Social Policy
Ministry of Finance
Ministry of Science and Higher Education

Polish Agency of Information and Foreign Investment
Polish Agency for Entrepreneurship Development
Public finance sector entities
State Accreditations Committee
Polish Classification of Activities
Regional Chamber of Audits
Accountants Association in Poland
Small and Medium Enterprises
Shared Service Center
Territorial self-government unit

v


ACKNOWLEDGEMENTS
This report was prepared by the World Bank Centre for Financial Reporting Reform based on
the findings of a study undertaken in Poland in 2014 by Dr Małgorzata Kamieniecka and Dr
Agnieszka Nóżka, Department of Accounting, Faculty of Economics, Maria Curie-Skłodowska
University (Uniwersytet Marii Curie-Skłodowskiej, UMCS) in Lublin; and Dr Krzysztof
Markowski, Director of Statistical Office in Lublin and lecturer at the Faculty of Social Sciences,
Department of Economics and Management of the Catholic University of Lublin of John Paul
II. The World Bank team was led by Alexander Fawcett, Sr. Financial Management Specialist
and included consultant Piotr Pyziak. Henri Fortin, Head of the CFRR and Andrei Busuioc, Sr.
Financial Management Specialist, provided guidance to the team.
The team wishes to thank: Joelle Le Vourc'h, Professor of International Accounting in ESCP
Europe Business School in Paris, France; Henri Olivier - retired Professor from University of
Liege, Belgium; John McDonagh – education expert; Ewa Korczyc, Country Economist for
Poland, World Bank and Szymon Radziszewicz, Senior Technical Manager, Member Body
Development, International Federation of Accountants for their comments on the draft
report.

Similarly, the team expresses thanks to Ismail Radwan, Country Program Coordinator,
Central/South Europe and Baltics, for his guidance and support provided.
The team is grateful for the extensive cooperation and assistance received in Poland from the
staff of the Ministry of Finance, the Statutory Chamber of Auditors and the Accountants
Association.
The study and report are part of the Financial Reporting Technical Assistance Program (FRTAP)
managed by the Centre for Financial Reporting Reform with funding provided to the
Government of Poland by the Swiss Enlargement Contribution.
The report was cleared for publication by the Ministry of Finance in June 2014.

Regional Vice President:

Laura Tuck

Country Director:

Mamta Murthi

Practice Director:

Samia Msadek

Practice Manager/Head of CFRR:

Soukeyna Kane/Henri Fortin

Task Team Leader:

Alex Fawcett/Andrei Busuioc

vi


EXECUTIVE SUMMARY
The Accounting Market Study was conducted under the Financial Reporting Technical
Assistance Program (FRTAP) managed by the Centre for Financial Reporting Reform (CFRR),
with funding provided to the Government of Poland by the Swiss Enlargement Contribution.
This activity is consistent with the focus of the Bank’s strategy to assist government in
strengthening governance and institutions and to tackle issues of competitiveness. In
addition, the delivery of AAA knowledge products is part of the Bank’s operational response
to the increasing demand of governments for knowledge products.

Financial Reporting Technical Assistance Program
The Financial Reporting Technical Assistance Program (FRTAP or the Program) for Poland is
part of the broader Swiss Contribution to Reduce Economic and Social Disparities within the
enlarged European Union for the 2004 and 2007 cohorts of new EU Member States (the
Enlargement Contribution).
The main objective of the Program is to support Poland in putting in place sustainable
regulatory and institutional frameworks which (a) correctly implement the acquis
communautaire in the field of corporate sector financial reporting; (b) properly monitor and
enforce the application of the acquis in practice; and (c) provide necessary education and
training of individuals responsible for those tasks.

The Study
The Study was prepared by a team comprising university teachers from Maria CurieSkłodowska University (Uniwersytet Marii Curie-Skłodowskiej, UMCS) in Lublin and the
Director Statistical Office in Lublin.
The Study has been designed to provide relevant information for multiple uses, including the
gathering of statistics for IFAC, and offer quantitative information and feedback on aspects of
the functioning of the accounting market to better understand the market for regulatory
purposes. The data can be used to inform policy formulation and decision-making related to

the regulation of financial reporting (both domestically and as part of Poland’s participation
in EU and international regulatory processes) and to the functioning of the market for
accounting services.
This report was presented to a representative stakeholder group in Warsaw in 2014, including
the Ministry of Finance, the Accountants Association in Poland and the Chamber of Statutory

1


Auditors of Poland. The Accounting Market Study is the first step, it is expected to be followed
by a study of the auditing market.

Structure and content of the report
Section 1 - The Introduction lays out the team’s approach to achieve the objective of the
study (see section “I.1. Introduction” for further details of the objective) along with a broad
descriptor of the stakeholders, including: Government, Professional Bodies, Oversight,
Training organisations, Industry groups, business groups, accountants and auditors, etc. The
research methods used include desk, international report review, diagnostic survey, heuristic,
descriptive, analytical, simple statistical and table/graphical presentation of data.
Section 2 - Professions related to Accounting and Auditing covered the Law and other
regulations, statistical classification of the profession, including tax advisor, auditor (internal
and external) and bookkeeping services plus cross-border recognition in the European Union.
Data is presented on teachers to the profession in Poland along with the locations of the
subject matter in the particular disciplines related to accounting and auditing. There is a
comparison of the notion ‘accountant’ in France, Norway, Italy, United Kingdom, Hungary,
Spain, Netherlands, Germany and Sweden with a table of national requirements.
Section 3 - This part deals with the supply and demand equation and Poland needs to be
aware of the pipeline of human resources and the level of quality of teaching being delivered.
This section on Education paths of the accounting profession provide data on the education
sector (both Secondary and post-secondary) in Poland leading to professional education with

a comparison with ACCA and CIMA. There is significant data on student numbers as well as
comments on education quality. The Accountants Association is the principle source for
student numbers, curriculum and geographical spread across Poland. International
qualifications such as ACCA and CIMA continue to be popular with constant annual growth
since 2000. A summary of other qualifications attached to the accounting profession are
summarised for completeness.
Section 4 - In this section the team researches the Labour Market for Accounting and
Auditing professionals. This is the largest section of report. The section begins with a market
analysis of accounting services in Poland and then moves to an employment analysis, the
impact of the SME sector on the labour market and then critically examines, both
quantitatively and qualitatively, the market for the regulated professions of: Statutory
auditors, Tax advisors, Accounting certificate holders, Chief accountants and internal auditors
in the public sector. This section finishes with broad look at the outsourcing market (a key
area of growth for the Polish economy), key aspects and comparisons with compensation and
a round-up on the issue of unemployment.

2


Section 5 - The authors of this report take a look at the changing political and economic
landscape in the wake of the 2008 financial crisis and the impact that this has had on many
areas of the profession. New Trends and the direction of changes planned for the Market is
an opinion driven rather than research led and brings together a number of interesting
influences on the shape and complexity of the market in Poland. With the backdrop of
Poland’s entry to the European Union and the impact of the various Directives, the report
looks at the impact of deregulation, the new types of accounting services likely to be in
demand in the future and also the new trends in accounting education. Key views:


The change in approach to the education of accountants and auditors and changing it

so as to form deeper ties with the economy and make it more practical; this is
particularly true with respect to formal education (competency based).



The factor determining further changes in the accounting market are the deregulation
processes announced or planned by the government. For example, currently we can
see many initiatives and actions undertaken by market participants (first and foremost
education institutions) aimed at adjusting to change, although concerns about results
of deregulation1 (especially from owners of accounting and auditing companies) remain
rather significant.

Section 6 - The key sources and the scope of data concerning the accounting and auditing
(A&A) in Poland are described. The methodology behind GUS research is briefly discussed and
outlined in order to enable proper interpretation of statistics based on research findings.
Statistical data used in the report refers to first half of 2013 or other periods, depending on
the source as mentioned in referrals.
The structure of research forms and GUS statistical returns has been analyzed with the
purpose to diagnose the scope of data gathered from the market. Recommendations for
improvements in the current GUS system of data collection and in the quality of information
obtained, have been suggested. The sources of data pertaining to accounting and audit
market other than the data collected by GUS are also summarized. They are presented in
tables, separately for each stakeholder/stakeholder group. A detailed scope of collected
information has been defined for each category, side by side with information presentation
form, frequency of updates, and accessibility. Whenever appropriate, recommendations for
improvements in data presentation and/or scope have been put forward.

1

Deregulation is a process of revising and reducing unnecessary burden and restrictions imposed earlier on

selected professions. Liberalization of regulated professions in Poland, between 2013-2015 involved
elimination of some burdensome and unnecessary laws and regulations that hinder access to professions. As a
result of deregulation, the access to professions is more transparent, more market driven and to some extent
easier than before.

3


Key Findings
The term Accountant in Poland does not have a single
definition and is not homogenous. It consists of many
professions listed in the Classification of Professions and
Specializations (CPS) used by the labour market, requiring
varied competences, responsibilities and education. Sometimes the names of the professions
and specializations in Polish CPS are not aligned with names applied in enterprises and
institutions. There is no single institution in Poland responsible for organizing, coordinating
or controlling this market in a comprehensive manner, which could be a reliable source of
relevant information. The strong cooperation of Ministry of Finance, Statistical Office (GUS)
and professional associations of accoutants in Poland would create a strong environment for
defigning and capturing the profession better.
The term Accountant does
not have a single definition
and is not homogenous

The more senior the position in the organizational structure
and the larger the entity, the higher the requirements of
employers for a professional accountant in Poland. The
requirements for accountants employed in smaller
companies can be much lower but high levels of skills and
knowledge are just as important, especially as frequently one person is responsible for

financial reporting, payroll, tax returns, HR matters and preparing reports for the
management. Regardless of profession and position, one of most important requirements for
the appropriate performance of tasks is practical experience.
Skills and knowledge
requirements vary
according to the job
position

Based on data available from the statistical office (GUS),
policy makers can identify the number of persons who
attended secondary schools in economics-administration
sub-group majors, and graduated from them [Table 3.2.,
section 3.2 of the report]. The same applies to students of
higher education of economics-administration [Table section 3.3 of the report]. However,
there is no data on how many of these graduates go on to work in the profession. The only,
imperfect, way of finding this out is to use regional Labor Office reports or national Ministry
of Labor and Social Policy reports on shortages and surpluses of professionals to determine
how many people registered as unemployed and the level of demand from enterprises for
“basic” professions. This monitorig shortage does not allow to assess the real demand of the
market for new accountants and perception of quality of their education.
Statistical data is available
for students but not for
how many then enter the
accounting profession

The quality of economic
education has improved
and should continue
improving in the future

State Accreditation Committee (SAC) reports over the past
three years confirm that the quality of education on
economic majors has improved. The quality is better in public
schools than private schools. SAC report that the finance and
accounting major has a strong identity, both in terms of the

4


academic specializations of quality academic teachers constituting the staffing minimum
requirements, and teaching standards. However, knowledge of accounting principles and
provisions of the tax law are not enough to effectively practice the profession. The education
system has to prepare graduates to take a comprehensive approach to all aspects of the
enterprise’s operation, from handling data and forecasting to managing teams. The economic
transactions are becoming more complicated and constantly improving accounting education
should prepare future accountants to cope with the more challenging business environment.
Moves are underway to overhaul the professional formal
education of accountants and auditors and make it more
competency based – which is in line with recent
International Education Standards (IES) - and practical with
deeper ties to the economy. The deregulation processes has determined further development
in the accounting market in Poland [Section 5.2.D of the report]. Already a number of
initiatives and actions are being undertaken by accounting market participants (first and
foremost education institutions) aimed at adjusting to change and filling the void after
abandoning the accounting licenses issued by the Ministry of Finance. Significant concerns
about the results of deregulation, especially from owners of accounting and auditing
companies, remain.
Growing emphasis on
competency based
accounting education

Professional bodies including ACCA (1500 members and
3500 students), SKwP (20 thousand members, 7 thousand
professional certificates of level 1 issued, 6 thousand
certificates level 2, 2 thousand certificates level 3 and 113
level 4) and CIMA (2200 members and students) work with
tertiary schools to offer education paths that enable graduates (usually after a relevant
accreditation procedure) to get a pass for certain specified elements of qualification. Activities
of this type seem beneficial for all involved - the professional bodies gain new members,
tertiary schools’ teaching programs and methods are modernized, and students can develop
their knowledge and interest in accounting and obtain additional qualifications at no extra
cost.
There are a growing
number of qualification
initiatives for the
accounting profession

Due to data constraints, it is difficult to carry out a reliable
quantitative and qualitative analysis of demand and supply
in accounting market. The accounting
market is
heterogeneous and broad and those working in bookkeeping/accounting need not have an accounting
education/qualification.
A
more
consistent
and
comprehensive image of the market could be obtained with closer cooperation and
knowledge sharing among stakeholders, and with the establishment of a common framework
for data sharing among all interested parties. The demand for high quality financial reporting

and related demand for monitoring and enforcement is still strong and there are no signs for
Reliable quantitative and
qualitative analysis of
demand and supply in
accounting and audit is
difficult

5


oversupply of accountants. It would be very useful to have a tool allowing analyzing trends
and measuring current situation.
GUS collects statistical data regarding the accountancy
market. The approach is rather general, including only
selected aspects of the market, and imperfect, based on
outdated assumptions and does not reflect recent market
changes, e.g. outsourcing is not included. These deficiences
result in a blurring of the overall picture. Recommendations on changes to collected by GUS
for statistical purposesd have been made to improve the quality of information obtained
through updating existing statistical forms without imposing an additional bureaucratic
burden on entities [Section 6.2 of the report].
Statistical data regarding
the accountancy market is
imperfect and requires
revision

The outsourcing services industry is growing and offers a
range of employment opportunities. Poland has become 3rd
biggest center for outsourcing in the world after China and
India with over 650 business service centers employing over

150,000 accountants. The location of new Business Process
Outsourcing (BPO) and Shared Service Center (SSC) entities in Poland seems to depend more
on factors like access to personnel with preferred foreign language skills, access to real estate
and other infrastructure, open attitude of local government authorities and other amenities,
including special economic zones, than on the vicinity of academic centers. Employees can
develop the required professional competences in an informal way (not necessarily through
university courses), and BPO/SSC entities often offer such training opportunities (e.g. in the
form of training and secondments abroad, in investor’s home country or another branch of
the company). Access to higher education facilities paired with the capacity of their
authorities to take sovereign decisions concerning the curricula may, however, result in an
offer of post-graduate courses and training programs for present-day and potential
employees of BPO/SSC entities.
Vibrant development of
the outsourcing services
sector offers training
opportunities

There is growth in the range and use of online accounting
services, and accounting solutions provided by banks,
primarily geared towards SME. The purchase and use of
licensed software packages is being replaced by online
software. New solutions include data processing in the
“cloud” – move from computers and servers in the local network to highly specialized data
processing centers. Another new feature offered by banks is accounting services integrated,
or capable of integration, with a bank account.
Emergence of online
accounting services and
accounting services offered
by banks

The Government has already revised existing legislation and
made some changes to the limitations of selected
professions, including statutory auditors, tax advisors, and
bookkeeping service providers. The changes lifted some bureaucratic barriers and
Deregulation of the
accounting profession

6


requirements, standardised the access to the professions and made it more transparent. The
changes made so far were in line with expectations of the market. It is expected that future
liberalisation of accounting profession would continue making the access to the profession
easier by elimination unnecessary burden and restrictions but without the risk of diminishing
the quality of accounting services in Poland and public trust in the accounting profession.

Deregulation of regulated professions in Poland
Poland had passed legislation deregulating many professions understood as liquidating
unnecessary requirements (such as exceedingly high license fees, and certificates) serving
the sole purpose of blocking access to a given profession. Nearly 240 professions have been
liberalized in three stages. The second stage of deregulation finalized by the “Act on
facilitating access to perform certain regulated professions”, dated 9 May 2014 affected
the accounting profession in Poland.
Main elements of the deregulation in accountancy profession included: (i) elimination of
requirement of tertiary specialized education or of tertiary supplemented by a postgraduate degree in accounting; (ii) forgoing the requirement of the state exam in favor of
self-regulation of the bookkeeping services market; (iii) elimination of requirement of
practical internship; (iv) elimination of requirement for accountant of having full extent of
public rights (not limited by decision of legal court)
Previous state certificate in accountancy was held by almost 100 thousand persons
(however it was not known how many of them actively used those certificates and worked

as accountants). As a result of deregulation, access to bookkeeping services activity has
been fully liberated.

7


CONCLUSIONS AND RECOMMENDATIONS
Section 4 of the report contains quantitative analysis of entities that employ own accountants
and companies that offer accounting and book-keeping services – these companies are the
basic work place for finance and accounting professionals. However, since accounting
departments/units/positions can be found in entities regardless of their classification (Polish
Classification of Activities/PKD code), sub-section 4.2. contains the analysis of employment in
the breakdown according to professions in the entire economy. The analysis is based on the
data derived from Poland’s Central Statistical Office (GUS) and it only pertains to mediumsized and large companies, which is why in sub-section 4.3. the authors attempt to
supplement the employment information with the data pertaining to the SMEs (which either
have in-house finance and accounting staff, or outsource such services with accounting firms,
which is quite a common practice.)

Eliminating information gaps
Review of sources of data/information about A&A market has allowed formulation of
preliminary alternative recommendations with respect to eliminating identified information
gaps:


The most beneficial one (providing the most complete and accurate picture) would be
to prepare a new permanent or cyclical survey, (included in GUS research program).
Such a survey would enable monitoring changes in A&A market, although due to
obligation of observing obligatory procedures with respect to preparation of Public
Statistical Research Program it would be very time consuming, labor intensive and costly
(time for obtaining results and their analysis, as well as cost of the survey would depend

on the scope of survey, its complexity, size of sample as well as depth level of analyses;
relevant calculations for results and/or analysis thereof could be performed by GUS
and/or MoF employees, or a specially formed team of experts); or



Introducing specific modifications in forms currently utilized by GUS (while maintaining
GUS procedures) – detailed proposals in this scope are described in section 6.2 of the
report; or



Commissioning GUS (outside the statistical research program) or another independent
research team, a separate survey, incidental or repeated at a specified interval, e.g. 3 or
5 years; this solution would be possible to implement over a relatively short period of
time; in case of an incidental survey, it would only provide a snapshot (diagnosis) of the
A&A market at a given moment; a cyclical survey would enable monitoring of changes
(analysis of survey results, as in previous case, could be performed by various teams).

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Regardless of which method of filling the information gap is selected, the authors would like
to point out the need for preparing the survey methodology in such a way that it would
include the microenterprises segment, which, as has been shown in the report, plays an
important role in creating demand for accounting services and in currently collected data it is
hardly taken into consideration.
The full picture of the accounting market in Poland and better understanding of market forces
affecting its development of the accounting profession could be drawn from reading the
whole report. The key points raised by the report are:



Based on the analysis it can be concluded that accountancy market in Poland is
heterogeneous, complex and fragmented. This is largely a consequence of the fact
that there is no single institution in Poland responsible for organizing, coordinating or
controlling this market in a comprehensive manner.



A more consistent and comprehensive image of the market of accounting and auditing
services could be obtained if the stakeholders embarked on closer cooperation and
knowledge sharing, and if common framework was established for data sharing policy
for the benefit of all interested parties.

The GUS data collection system continues to be the best source of information about
various areas of accountancy market, once certain adjustments to some forms are made. It
is the cheapest solution, but it does not offer such potential in terms of data granularity and
comprehensiveness as a targeted survey done on commission.

Companies offering accounting and book-keeping
services
Statistical data collected by GUS for companies, which main activity is legal, accounting &
book-keeping and tax advisory services is not detailed enough. According to REGON register,
as of July 31, 2013, there were 88 305 entities operating under classification number 69 (law,
accounting & book-keeping and tax advisory services), representing 2.2% of all the entities in
the national economy.
The code assigned to the provision of A&A services is 69.20.Z – ‘Accounting and Book-keeping
Activity; Tax Advisory Services’. This category includes, inter alia, accountancy firms and
outsourcing centers. As of March 31, 2013, 45 250 active entities from that industry were
listed in REGON register.

97.4% entities of active entities from the code 69.20.Z employed between 0 and 9 people;
2.4% entities - between 10 and 49 people; 0.10% entities employed 50 - 249 people; 0.04%

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entities employed more than 250 people. GUS statistics does not provide detailed data
regarding number of accountants working in 69.20.Z category entities.
It is important to note that the entities coded under 69.20Z include both the entities offering
book-keeping and accounting services (accountancy firms), and the entities offering tax
advisory and financial statement audit services. GUS statistics do not allow for separation of
these three types of accounting services from one another, and they do not show which
entities combine any of these functions (e.g. offering audit and tax advisory services and/or
book-keeping/accounting services.)

Analysis of employment in the breakdown according to
accounting professions in the entire economy
Statistical data collected by GUS for types of professions, including accountants, from all
companies is incomplete and fragmented. Quite a lot of information about the quantity and
quality of people working on the market of accounting services can be obtained on the
Internet and from accountancy organizations and associations. However, all these
specifications present but a fragment of the entire picture. They are approximate and
incomplete, generally speaking. Among many different studies carried out by GUS in the field
of the labor market, there is a study focused on the structure of compensation (wages) by
profession, dated October 20102. It is a representative survey (meaning that data collected
from certain number of companies is being extrapolated to the population of the companies,
as the whole) carried out every two years in firms that employ more than nine people, i.e. in
medium-sized and large enterprises. This particular study is quite informative as far as the
number, educational attainments and place of employment of the population of people
involved in broadly defined accounting services are concerned. However, the major weakness

of this study is that the micro entities employing less than 9 people are not subject to
statistical analysis and the total number of accountants might be affected by this lack of
information.
Table 4.4. Structure of people employed according to ‘elementary’ occupational groups, in
October 2010 shows that 617 thousand people worked in accounting field, which represented
7.7% of all people in employment. The number mentioned above includes accountants
working in companies of the statistical group 69.20.Z, however only those employing more
than 9 people. Also based on data from Table 4.4, vast majority of elementary groups listed
in the table are dominated by women. This is especially true about such groups as

2

GUS report: „Struktura wynagrodzeń według zawodów w październiku 2012 r.” [‘Compensation structure by
occupation in October 2012’],
/>_wg_zawodow_10_20121.pdf.

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‘accountants’, where women account for 94.6%. By the same token, women (93.2%)
definitely outnumber men in the elementary group labelled as ‘accounting and book-keeping
employees’. This group includes people working as accounting assistants, accounting clerks,
or accounting technicians. The third elementary group with high prevalence of female over
male employees is the group labelled as ‘financial managers’ - comprised of employees
working as chief accountants, managers of accountancy firms, or financial department
managers. According to GUS research findings, women occupy 90% of mid-level managerial
positions in the field of book-keeping services. The group of book-keeping and accounting
specialists has an equally high share of female employees - women represent 84.5% of all
employees in that group. To put it in different words, statistically speaking, every fifth bookkeeping and accounting specialist is male. The only group where men outnumber women is
“general and executive directors”, and “managers in service institutions”.

Apart from two elementary groups, majority of the remaining people work in the private
sector. In the case of groups such as: ‘General and Executive Directors’, ‘Financial and
Investment Advisors’, and ‘Accounting and Book-keeping Employees’, vast majority is
employed in the private sector.
The following observations can be inferred from the study referred to above:


Women have a prevalent role in accounting professions. This is particularly true about
such elementary groups as financial managers, accounting and book-keeping specialists,
accountants, and accounting and book-keeping employees.



The biggest number of people employed in accounting professions can be found in
Mazowieckie, Śląskie, Wielkopolskie, Małopolskie and Dolnośląskie. This is to be
expected, given the number of business entities in those regions.

GUS research into salary structure by occupation, carried out in October 2010, turns out to
be most informative as far as the number of people working in accounting professions are
concerned. Yet, due to the focus of this study, i.e. the structure of compensation for different
professions, and the sampling methodology applicable to people working in national
economy entities (relevant for the key focus of the study), the population of people working
in accounting professions is susceptible to serious errors arising from estimation. Another
reason underlying the errors in estimating the number of people working in each profession
is the fact that in many entities included in the research there is no accounting clerk position,
and accounting clerk job is done by a person hired in another capacity – e.g., by an
administrative employee. Population working in different professions is less susceptible to
error in the so-called large occupational groups. The smaller the group, the greater the
estimation error, due to reasons listed above. Additionally, information about people working
in accounting professions does not include micro-enterprises, which account for 95.6% in

Poland, and more than 44 thousand micro-enterprises report activity coded as 69.20.Z as their
core business. At present, there is no information on the number of firms in Poland that offer
book-keeping and accounting services (69.20.Z) as a second or third line of operation, or on
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the population of employees involved in that operation. Such information might become
available if GUS had appropriate software developed, in line with the terms described in
Section 6.2.

Impact of the SME sector on labour market for
accountants
Incomplete and fragmented statistical data regarding the need for accounting services
generated by SME sector. Significance of the SME sector for accountancy market may result
from the fact that SMEs create demand and, at the same time, they impact the supply of
accountancy professions and services. Demand is created when SMEs:


Hire accountants as full time employees, part-time employees, or under job
performance contracts,



Are the clients of accountancy firms and, potentially, BPO/SSC firms

There were about 4.033 million entities in Poland at the time of preparation of the report.
Business entities coded 69 (law, accounting & book-keeping and tax advisory services)
amounted to 88 thousand units. Entities other than coded 69 amounted to 3.945 million.
Majority of the total number of entities were private entities – 96,9%. The lion’s share of
national economy entities are the entities that employ up to 9 people, i.e. micro-enterprises

as per GUS definition (they accounted for about 95.6% of all registered entities), followed by
small enterprises (3.5%) employing between 10 and 49 people, and medium-sized companies
with 50 - 249 employees (0.7%.). tax revenue and expense ledger have been the predominant
type of accounting records micro enterprises and SME.
The review of the micro and SME sector through the prism of their accounting records allows
for very general conclusions regarding the demand for accountants or accounting services
(accountancy firms or BPO/SSC) in that sector. Available and published data and reports
(mostly GUS) give no direct indication as to the population (percentage) of SMEs which
outsource their accounting record-keeping vs. those that do it in house, although individual
tax offices do have such data about their taxpayers. The data available does not give any
indication regarding the number of accountants working in micro companies – employing
less than 9 people. Given the lack of access to information stored in Central Register of
Entities in National Register of Taxpayers (CRP KEP), or to the data from 400 tax offices in
Poland, it is not possible to analyze current demand for accounting services among SMEs.
Independent such analyses and reports provide some interesting data about accounting in
micro-, small and medium-sized enterprises (Review of On-line Accounting Services from 2012
prepared by Starter Business Development Foundation), though the reader may have some
doubts about the quality of data in the reports: research methodology have not been
described, and secondly it is based on another piece of research, quoting the data without
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clear indication as to whether the data is derived from one source, or from several sources.
Starter Foundation claims that 51% (i.e. 903 thousand) of micro- and small enterprises in 2011
used the services of external accountancy firms, 12% (212 thousand) employed accountants
in house, and 37% of entrepreneurs did their own accounting (incl. 9% with the use of on-line
applications and 12% planning to take up on-line accounting applications).
The study involved 450 entrepreneurs representing firms employing between 0 and 49
people, from all over the country. Research was done as an Internet survey, however the
study cannot be regarded as representative due to insufficient number of entities.

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FOREWORD
The objective of this first study on accounting in Poland is to (a) map and scope out the
existing information infrastructure pertaining to accounting market and accounting
profession; (b) identify information gaps – areas where the is lack of information or the
quality of existing information is not good; (c) suggest approaches to bridge existing gaps
and to could improve the quality of information; and (d) to give recommendations to the
government how to strengthen accounting profession, improve the quality of the services
and to assist the government with the implementation of recommended actions. To achieve
this objectives, the Accounting Market study is focusing on reviewing areas where the
collection of regular data would positively influence policy formulation and decision-making
for the regulation of financial reporting in Poland, while enhancing the competitiveness of
Polish enterprises. CFRR hopes to assist the relevant Polish institutions to develop and
implement a sustainable and integrated system for the regular collection and analysis of
statistical data about the accounting profession in Poland.
Uniqueness and associated risks. This study, is not just unique to Poland but to the rest of
the EU and the world, so whilst attractive to assist the Government of Poland in their desire
to deepen their knowledge of this important market, the inherent risk cannot be understated.
This study could set the standard for other countries of the world whose Government’s wish
to capture this potentially important data as evidenced policy making.
University and State Statistics Office participation. The overriding and urgent need was to
actively engage with a University of standing in the area of research methodology and data
mining that will work closely with the task team and the State Statistics Office. The quality
and quantity of data currently available inside Poland has yet to be determined but the
importance of the accounting market is underscored by growth of Polish economy and the
growing need for high-quality accounting services, including accounting outsourcing business
where Poland’s place in the world stage is rising strongly and many of these jobs are claimed

to be in the accountancy market.
Poland has been a member state of the European Union since 2004; it has not adopted the
Euro. Poland is in central Europe, with a coastline on the Baltic Sea in the north. It is shares
its borders with numerous countries: Germany, Czech Republic, Slovakia, Ukraine, Belarus,
Lithuania, and Russia. The capital and largest city is Warsaw. Poland has a stable population
of about 38.2 million. Its 2012 Gross Domestic Product (GDP) per capita was US$12,708; 3
almost double what it was when Poland acceded to the EU (US$6,620 in 2004). This is still

3

GDP per capital in current US$. Source: World Development Indicators, World Bank.

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