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UHY ECA Audyt Sp. z o.o.
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INDEPENDENT AUDITOR’S REPORT ON THE AUDIT
For the General Meeng and Supervisory Board of DataWalk S.A.
Report on the audit of the annual consolidated financial statements
Opinion
We have audited the annual consolidated financial statements of DataWalk Capital Group (the ‘Group’),
in which the parent company is DataWalk S.A. (the ‘Parent Company’), which comprise the
consolidated statement of financial posion as at 31 December 2025 and the consolidated income
statement, together with the statement of comprehensive income, consolidated statement of changes
in equity, consolidated statement of cash flows for the financial year from 1 January to 31 December
2025 and selected notes, explanatory notes and other explanatory notes to the consolidated financial
statements (the ‘consolidated financial statements’).
In our opinion, the accompanying consolidated financial statements:
give a true and fair view of the consolidated property and financial posion of the Group as at
31 December 2025 and of its consolidated financial performance and its consolidated cash
flows for the year then ended in accordance with required applicable rules of Internaonal
Financial Reporng Standards approved by the European Union (IFRSs) and with the
accounng principles (policy) adopted;
comply in respect of the form and content with laws applicable to the Group and the Parent
Company’s Statute.
This opinion is consistent with the addional report to the Audit Commiee issued on 30 March 2026.
Basis for opinion
We conducted our audit in accordance with the Naonal Auding Standards in the wording of the
Internaonal Auding Standards adopted by Resoluon No. 3430/52a/2019 of the Naonal Council of
Statutory Auditors of 21 March 2019 on naonal auding standards and other documents, as
amended, and the Resoluon of the Board of the Polish Agency for Audit Oversight No. 38/I/2022 of
15 November 2022 on naonal quality control standards and Naonal Auding Standard 220
(Amended) (‘NAS’), as well as pursuant to the Act of 11 May 2017 on Statutory Auditors, Audit Firms
and Public Oversight (i.e. Journal of Laws of 2025 item 1891 – the ‘Act on Statutory Auditors’) and the
Regulaon (EU) No. 537/2014 of 16 April 2014 on specific requirements regarding statutory audit of
public interest enes (Official Journal of the European Union UE L158 of 27 May 2014, p. 77, as
amended the ‘EU Regulaon’). Our responsibilies under those standards are further described in
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UHY ECA Audyt Sp. z o.o.
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the Auditor's responsibilies for the audit of the consolidated financial statements’ secon of our
report.
We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis
for our opinion.
Independence and ethics
We are independent of the Group companies in accordance with the Internaonal Code of Ethics for
Professional Accountants (including Internaonal Independence Standards) of the Internaonal Ethics
Standards Board for Accountants adopted by resoluon of the Naonal Council of Statutory Auditors
No. 3431/52a/2019 of 25 March 2019 on the principles of professional ethics of statutory auditors,
as amended (the ‘IESBA Code’) and with other ethical requirements that are relevant to our audit of
financial statements in Poland. We have fulfilled our other ethical responsibilies in accordance with
those requirements and the IESBA Code. While conducng the audit, the key cerfied auditor and the
audit firm remained independent of the Group companies in accordance with the independence
requirements set out in the Act on Statutory Auditors and in the EU Regulaon.
Key Audit Maers
Key audit maers are those maers that, in our professional judgment, were of most significance in
our audit of the consolidated financial statements of the current period. They include the most
significant assessed risks of material misstatement, including the assessed risks of material
misstatement due to fraud. These maers were addressed in the context of our audit of the
consolidated financial statements as a whole, and in forming our opinion thereon and have
summarised our reacon to these risks and in cases where we deemed it necessary, we presented the
most important observaons related to these types of risks. We do not provide a separate opinion on
these maers.
Key Audit Matter How our audit responded to this matter
COMPLETED DEVELOPMENT WORKS
The Group carried out development work in
prior periods relating to the development of
information technology concerning a business
asset understood as the DataWalk platform. As
at 31 December 2025, the Group recognises
completed development costs in its
consolidated financial statements amounting to
TPLN 15,696, representing 14.5 % of total assets.
Our procedures on the identified key audit
matter included, but were not limited to, the
following:
obtaining an understanding and evaluating the
process for identification, approval and
classification of development expenditures as
intangible assets, including in relation to assets
brought into use in 2025,
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In the current year, the Group decided to cease
capitalisation of development costs. The
completed development costs recognised in the
consolidated financial statements were subject
to an impairment test, the performance of which
required the application of significant
management judgment and estimates, in
particular with respect to projected future cash
flows and the assumptions adopted.
This matter was considered a key audit matter
due to the materiality of the carrying amount of
the asset, the change in the Group’s approach to
the capitalisation of development costs, and the
high level of management judgment involved in
performing the impairment test.
Reference to disclosures in the consolidated
financial statements
Details regarding the capitalisation of
development expenditures (including
information on the results of the impairment
test performed) are disclosed in notes 2.1, 2.2,
2.3, 2.4 and 29 to the consolidated financial
statements, while the accounting policies are
described in the explanatory notes to the
consolidated financial statements.
verifying the compliance of the Group’s
accounting policies with the requirements of
IAS 38, including with respect to the cessation
of further capitalisation of development costs,
performing detailed substantive procedures
regarding the accuracy of allocation and
completeness of development expenditures,
including costs capitalised in the current
period,
evaluating the impairment test performed,
including its mathematical accuracy, the
reasonableness of key assumptions adopted
and the consistency of financial projections
with the Group’s approved plans,
performing sensitivity analysis of the test to
changes in key assumptions, in particular the
level of projected cash flows and the discount
rate,
discussing with the Management of the parent
company and other authorised personnel the
key assumptions adopted for the impairment
test and the rationale for ceasing further
capitalisation of costs,
analysing the disclosures included in the
consolidated financial statements with respect
to completed development costs and the
impairment test performed.
SALES REVENUES
The procedures we performed at the entity
understanding stage, together with our data
analysis, resulted in the identification of a risk
related to the recognition and measurement of
revenue from sales. The risk of improper
revenue recognition may arise in particular from
fraud involving the recognition of revenue from
the sale of goods and services in an incorrect
period.
Our procedures on the identified key audit
matter included, but were not limited to, the
following:
reviewing the accounting policies related to
revenue recognition and assessing their
compliance with IFRS 15,
obtaining an understanding of the sales
process and evaluating the design and
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This matter was considered a key audit matter
due to the materiality of the amounts involved,
as well as the fact that the method of recognising
and measuring revenue in the consolidated
financial statements requires significant
estimates and management judgment.
Reference to disclosures in the consolidated
financial statements
Disclosures relating to detailed information on
revenue are presented in notes 22.1, 22.2, 22.3
and 22.4 to the consolidated financial
statements, while the accounting policies are
described in the explanatory notes to the
consolidated financial statements.
implementation of internal controls in this
area,
performing analytical procedures, in particular
analysing monthly data and trends,
performing detailed substantive testing of
revenue recognised during the year based on
a selected sample,
testing a sample of transactions around the
year-end (December 2025 / January 2026) and
independently assessing the appropriateness
of revenue recognition by reference to
supporting documentation,
obtaining confirmations of receivables
balances from a selected sample of customers
as at the reporting date,
analysing unusual transactions and revenue
adjustments recorded after the reporting
date,
assessing the adequacy of revenue-related
disclosures in light of the requirements of IFRS
15 in the consolidated financial statements.
Responsibilies of the Parent Companys Management and members of the Supervisory Board for the
consolidated financial statements
The Parent Company’s Management is responsible for the preparaon of the consolidated financial
statements that give a true and fair view of the property and financial posion of the Group and of its
financial performance in accordance with the required applicable rules of Internaonal Financial
Reporng Standards approved by the European Union, the adopted accounng principles (policy) and
with the Group’s applicable legal regulaons and Statute and is also responsible for such internal
control as the Parent Company’s Management determines is necessary to enable the preparaon of
the consolidated financial statements that are free from material misstatement, whether due to fraud
or error.
In preparing the consolidated financial statements, the Parent Company's Management is responsible
for assessing the Group's ability to connue as a going concern, disclosing, as applicable, maers
related to going concern and using the going concern basis of accounng unless the Parent Company’s
Management either intends to liquidate the Group or to cease operaons, or has no realisc alternave
but to do so.
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The Parent Company’s Management and members of the Supervisory Board are required to ensure
that the consolidated financial statements meet the requirements of the Accounng Act of 29
September 1994 (i.e. Journal of Laws of 2023 item 120 as amended – the Accounng Act’). The
members of the Parent Company’s Supervisory Board are responsible for overseeing the financial
reporng process.
Auditor's responsibility for the audit of the consolidated financial statements
Our objecves are to obtain reasonable assurance about whether the consolidated nancial
statements as a whole are free from material misstatement, whether due to fraud or error, and to issue
an auditors report that includes our opinion. Reasonable assurance is a high level of assurance, but is
not a guarantee that an audit conducted in accordance with NAS will always detect a material
misstatement when it exists. Misstatements may arise as a result of fraud or error and are considered
material if they, individually or in the aggregate, could reasonably be expected to influence the
economic decisions of users taken on the basis of these consolidated financial statements.
The scope of the audit does not include assurance on the future profitability of the Group nor efficiency
or effecveness of conducng business maers now or in the future by the Parent Company’s
Management.
As part of an audit in accordance with NAS, we use professional judgment and maintain professional
scepcism and we also:
idenfy and assess the risks of material misstatement of the consolidated financial statements,
whether due to fraud or error, design and perform audit procedures responsive to those risks,
and obtain audit evidence that is sufficient and appropriate to provide a basis for our opinion.
The risk of not detecng a material misstatement resulng from fraud is higher than for one
resulng from error, as fraud may involve collusion, forgery, intenonal omissions,
misrepresentaons or override of internal control;
obtain an understanding of internal control relevant to the audit in order to design audit
procedures that are appropriate in the circumstances, but not for the purpose of expressing an
opinion on the effecveness of the Group’s internal control;
evaluate the appropriateness of accounng principles (policy) used and the reasonableness of
accounng esmates and related disclosures made by the Parent Company’s Management;
conclude on the appropriateness of the Parent Company’s Management’s use of the going
concern basis of accounng and, based on the audit evidence obtained, whether a material
uncertainty exists related to events or condions that may cast significant doubt on the Group’s
ability to connue as a going concern. If we conclude that a material uncertainty exists, we are
required to draw aenon in our independent auditors report to the related disclosures in the
consolidated financial statements or, if such disclosures are inadequate, to modify our opinion.
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UHY ECA Audyt Sp. z o.o. – member of UHY International, a network of independent accounting and consulting firms
UHY ECA Audyt Sp. z o.o.
Połczyńska 31A
01-377 Warszawa
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Our conclusions are based on the audit evidence obtained up to the date of our independent
auditors report, however, future events or condions may cause the Group to cease to
connue as a going concern;
evaluate the overall presentaon, structure and content of the consolidated nancial
statements, including the disclosures, and whether the consolidated financial statements
represent the underlying transacons and events in a manner that achieves fair presentaon;
we obtain sufficient appropriate audit evidence regarding the financial informaon of enes
and business acvies within the Group for the purpose of expressing an opinion on the
consolidated financial statements. We are solely responsible for the direcon, supervision and
performance of the audit of the Group and we remain solely responsible for our audit opinion.
We communicate to the Parent Company’s Supervisory Board on, among other maers, the planned
scope and ming of the audit and significant audit findings, including any significant deficiencies in
internal control that we idenfy during our audit.
We also provide to the Parent Company’s Supervisory Board with a statement that we have complied
with relevant ethical requirements regarding independence, and communicate to them all
relaonships and other maers that may reasonably be thought to bear on our independence, and
where applicable, acons taken to eliminate threats or safeguards applied.
From the maers communicated to the Parent Company’s Supervisory Board, we determine those
maers that were of most significance in the audit of the consolidated financial statements of the
current period and are therefore the key audit maers. We describe these maers in our auditors
report unless law or regulaon precludes public disclosure about the maer or when, in extremely rare
circumstances, we determine that a maer should not be communicated in our report because the
adverse consequences of doing so would reasonably be expected to outweigh the public interest
benefits of such communicaon.
Other informaon, including Group Acvity Report
Other informaon
Other informaon comprises Group Acvity Report as at 31 December 2025 (the ‘Group Acvity
Report’) together with the representaon on applicaon of corporate governance, which are separate
elements of this Group Acvity Report, and the Annual Report for the financial year ended 31
December 2025 (the ‘Annual Report’) (together the ‘Other informaon’).
Responsibilies of the Parent Company’s Management and members of the Supervisory Board
The Parent Company’s Management is responsible for the preparaon of the Other informaon in
accordance with laws.
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The Parent Company’s Management and members of the Supervisory Board are required to ensure
that the Group Acvity Report with separate elements meets the requirements of the Accounng Act.
Auditor's responsibility
Our audit opinion on the consolidated nancial statements does not include the Other informaon.
In connecon with the audit of the consolidated financial statements, our responsibility is to read the
Other informaon and, in doing so, to consider, whether the Other informaon is materially
inconsistent with the consolidated financial statements or our knowledge obtained during the audit or
otherwise appears to be materially misstated. If, based on the work we have performed, we conclude
that there are material misstatements in this Other informaon, we are required to report that fact in
our independent auditors report.
We have nothing to report regarding Other Informaon.
Our responsibility in accordance with the Act on Statutory Auditors is also to issue an opinion on
whether the Group Acvity Report, to the extent not relevant to sustainability reporng, was prepared
in accordance with laws and that it is consistent with the informaon contained in the consolidated
financial statements. Moreover, we are required to issue an opinion on whether the Group has included
the required informaon in the representaon on applicaon of corporate governance.
We obtained the Group Acvity Report before the date of this audit report and the Annual Report will
be available aer that date. In the event that we idenfy a material misstatement in the Annual Report,
we are required to inform the Parent Company's Supervisory Board.
Opinion on the Group Acvity Report
Based on the work performed during our audit, in our opinion, the Group Acvity Report:
has been prepared in accordance with the arcle 49 of the Accounng Act and paragraph 73
of the Decree of the Minister of Finance of 6 June 2025 on current and periodic informaon
published by issuers of securies and condions for recognion as equivalent the informaon
required by laws of non-EU member states (Journal of Laws of 2025 item 755– ‘Decree on
current informaon’);
is consistent with the informaon contained in the consolidated financial statements.
Statement on the Group Acvity Report
We cerfy that, based on our knowledge of the Group and its environment obtained during our audit,
we have not idenfied material misstatements in the Group Acvity Report.
Opinion on the corporate governance representaon
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In our opinion, in the representaon on applicaon of corporate governance, the Group has included
informaon spulated in paragraph 72, secon 7, point 5 of the Decree on current informaon.
Moreover, in our opinion, the informaon spulated in paragraph 72, secon 7, point 5 leer c-f, h and
i of the Decree included in the representaon on applicaon of corporate governance is in accordance
with applicable laws and informaon included in the consolidated financial statements.
Report on other legal and regulatory requirements
Opinion on the compliance of the consolidated financial statements prepared in the single electronic
reporng format with the requirements of the regulaon on technical standards on the specificaon of
a single electronic reporng format.
As part of our audit of the consolidated financial statement, we were engaged to perform an assurance
engagement to obtain reasonable assurance in order to express an opinion on whether the
consolidated financial statements of the Group for the year ended 31 December 2025 prepared in the
single electronic reporng format including in the file named DAT-2025-31-12-1-pl (the ‘consolidated
financial statements in ESEF format’), was tagged in accordance with the regulaons specified in
Commission Delegated Regulaon (EU) No 2019/815 of 17 December 2018 supplemenng Direcve
2004/109/EC of the European Parliament and of the Council with regard to regulatory technical
standards on the specificaons of a single electronic reporng format (Official Journal of the European
Union UE L 143 of 29 May 2019, p. 1, as amended – the ‘ESEF Regulaon’).
Idenficaon of criteria and descripon of the object of the service
The consolidated nancial statements in ESEF format were prepared by the Parent Company’s
Management in order to meet the tagging and technical requirements of the single electronic reporng
format which are specified in the ESEF Regulaon.
The subject maer of our assurance engagement is the compliance verificaon of the consolidated
financial statements in ESEF format against the requirements of the ESEF Regulaons, while the
requirements specified in these regulaons represent, in our opinion, applicable criteria for us to
express an opinion providing reasonable assurance.
Responsibility of the Parent Companys Management and members of the Supervisory Board
The Parent Company’s Management is responsible for preparing of the consolidated financial
statements in ESEF format in accordance with the tagging and technical requirements of a single
electronic reporng format which are specified in the ESEF Regulaon. Such responsibility includes the
selecon and applicaon of appropriate XBRL tags using the taxonomy specified in these regulaons.
Responsibility of the Parent Company’s Management also includes designing, implemenng and
maintaining of such internal control as determined is necessary to enable the preparaon of the
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consolidated financial statements in ESEF format, free from material non-compliance with the
requirements of the ESEF Regulaon.
The members of the Parent Company’s Supervisory Board are responsible for overseeing the financial
reporng process, which includes the preparaon of financial statements in compliance with the form
in accordance with the governing legal regulaons.
Auditors responsibility
Our objecve was to express an opinion, based on the performed assurance engagement, providing
reasonable assurance, that the consolidated financial statements in ESEF format was tagged in
accordance with the ESEF requirements.
We have performed our assurance engagement in accordance with the Naonal Standard for
Assurance Engagements Other than Audit and Review 3001PL Audit of Financial Statements Prepared
in Single Electronic Reporng Format adopted by resoluon of the Naonal Council of Statutory
Auditors No. 1975/32a/2021 dated 17 December 2021 (‘NSAE 3001PL’) and, where applicable, in
accordance with the Naonal Standard on Assurance Engagements Other than Audit and Review 3000
(R) as set out in Internaonal Standard on Assurance Engagements 3000 (Revised) - Assurance
Engagements Other than Audits or Reviews of Historical Financial Informaon adopted by Resoluon
of the Naonal Council of Statutory Auditors No. 3436/52e/2019 of 8 April 2019, as amended (‘NSAE
3000 (R)’).
This standard requires the auditor to plan and perform procedures to obtain reasonable assurance that
the consolidated financial statements in ESEF format were prepared in accordance with specified
criteria.
Reasonable assurance is a high level of assurance but it is not guaranteed that the assurance
engagement conducted in accordance with NSAE 3001PL and, where appropriate, in accordance with
NSAE 3000 (R), will always detect material misstatement when it exists.
The selecon of procedures depends on the auditors professional judgement, including the
assessment of risk of material misstatement due to fraud or error. When performing risk assessments,
and in order to design procedures to be performed the auditor takes into consideraon the internal
controls related with the preparaon of the consolidated financial statements in ESEF format, which
can provide the auditor with sufficient and appropriate evidence. The assessment of the internal
controls was not performed for the purpose of expressing an opinion on the effecveness of its
operaon.
Summary of performed procedures
Procedures that were designed and performed by us included among others:
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obtaining an understanding of the process of preparaon of the consolidated financial
statements in ESEF format, including the process of selecon and applicaon of XBRL tags and
maintaining compliance with the ESEF Regulaon, including an understanding of the internal
control system mechanisms associated with this process;
reconciliaon of the tagged informaon included in the consolidated financial statements in
ESEF format to the audited consolidated financial statement;
assessment of the compliance with the technical standards on the specificaon of a single
electronic reporng format, including the use of the XTHML format, with the use of specialist
IT tools, assessing the completeness of tagging the informaon in the consolidated financial
statements in ESEF format with XBRL tags;
assessment whether the applied XBRL tags from the taxonomy specified by the ESEF
Regulaon were applied appropriately and that extensions to the elements in the taxonomy
specified in the ESEF regulaons were used when there were no suitable elements in the
taxonomy specified in the ESEF Regulaons;
evaluang of the anchoring of the taxonomy extensions to the elements in the taxonomy
specified by the ESEF Regulaons.
We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our
opinion on the performed assurance engagement on the tagging compliance with the requirements of
the ESEF Regulaon.
Ethical requirements, including independence
While performing the assurance engagement, the key cerfied auditor and the audit firm have
complied with the independence and other ethical requirements as specified by the Code of ethics.
The Code of ethics is based on the fundamental principles related to integrity, objecvity, professional
competence and due care, confidenality and professional behaviour. We have also complied with
other independence requirements and ethical responsibilies in accordance with required applicable
rules of such assurance engagement in Poland.
Quality control requirements
The audit firm applies the naonal quality control standards introduced by Resoluon of the Board of
the Polish Agency for Audit Oversight No. 38/I/2022 of 15 November 2022. Naonal Quality Control
Standard 1 in the wording of Internaonal Quality Management Standard (PL) 1 Quality Management
for Firms that Perform Audits or Reviews of Financial Statements, or Other Assurance or Related
Services Engagements requires the audit firm to design, implement and apply a quality management
system, including policies or procedures with regard to compliance with ethical requirements,
professional standards and applicable legal and regulatory requirements.
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UHY ECA Audyt Sp. z o.o. – member of UHY International, a network of independent accounting and consulting firms
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Opinion on compliance with the requirements of the ESEF Regulaon
The maers described above constute the basis for our opinion which is why our opinion should be
read in conjuncon with these maers.
In our opinion, the consolidated financial statements in ESEF format was prepared in all material
respect in accordance with the requirements of the ESEF Regulaons.
Representaon on the provision of non-audit services
To the best of our knowledge and belief, we declare that the non-audit services we have provided to
the Group comply with the laws and regulaons applicable in Poland and that we have not provided
non-audit services that are prohibited under Arcle 5 item 1 of the EU Regulaon and Arcle 136 of
the Act on Statutory Auditors. The non-audit services that we provided to the Group and its subsidiaries
during the audited period are listed under “Provision of permied non-audit services by the Auditor
of the Group Acvity Report.
Appointment of the audit firm
We were appointed for the audit of the Group’s consolidated financial statements based on the
resoluon of the Parent Company’s Supervisory Board dated 25 January 2024. This is the ninth year in
which we have conducted the audit of the Group’s consolidated financial statements, including the fih
year during which the parent company has been a public interest enty.
The key auditor responsible for the audit resulng in this independent auditor's report is Marta
Jankowska.
........................................................
No. in the register: 13498
acng on behalf of UHY ECA Audyt Spółka z ograniczoną odpowiedzialnością of Warsaw, Poland,
entered into the list of audit firms under entry No. 3886 on behalf of which the key auditor has audited
the consolidated financial statements.
Audit | Outsourcing | Tax | Consulng
UHY ECA Audyt Sp. z o.o. – member of UHY International, a network of independent accounting and consulting firms
UHY ECA Audyt Sp. z o.o.
Połczyńska 31A
01-377 Warszawa
E biuro@uhy-pl.com
uhy
-
pl.com
This document is a foreign language version of the original Independent Auditors Report issued in
Polish version and only the original version is binding. This document has been prepared for informaon
purposes and could be used only for Parent Company’s internal purposes. In case of any discrepancies
between the Polish and English version, the Polish version shall prevail.
Warsaw, 30.03.2026