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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
E biuro@uhy-pl.com
uhy
-
pl.com
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 separate financial statements
Opinion
We have audited the annual separate financial statements of DataWalk S.A. (the ‘Company’), which
comprise the statement of financial posion as at 31 December 2025 and the income statement,
together with the statement of comprehensive income, statement of changes in equity, 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 financial statements (the ‘separate financial statements’).
In our opinion, the accompanying separate financial statements:
give a true and fair view of the property and financial posion of the Company as at 31
December 2025 and of its financial performance and its 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 Company and its Statute;
have been prepared based on properly maintained accounng records, in accordance with
chapter 2 of the Accounng Act of 29 September 1994 (i.e. Journal of Laws of 2023 item 120
as amended – the ‘Accounng Act’).
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
the Auditor's responsibilies for the audit of the separate financial statements’ secon of our report.
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
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 Company 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 Company 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 separate 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 separate financial statements
as a whole, and in forming our opinion thereon and have summarised our reacon 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 Company 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 Company recognises
completed development costs in its separate
financial statements amounting to TPLN 15,696,
representing 18.2% of total assets.
In the current year, the Company decided to
cease capitalisation of development costs. The
completed development costs recognised in the
separate financial statements were subject to an
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,
verifying the compliance of the Company’s
accounting policies with the requirements of
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
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pl.com
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 Company’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 separate 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 separate financial
statements, while the accounting policies are
described in the explanatory notes to the
separate financial statements.
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 Company’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 Company’s Management
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
separate 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.
This matter was considered a key audit matter
due to the materiality of the amounts involved,
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
implementation of internal controls in this
area,
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
as well as the fact that the method of recognising
and measuring revenue in the separate financial
statements requires significant estimates and
management judgment.
Reference to disclosures in the separate financial
statements
Disclosures relating to detailed information on
revenue are presented in notes 22.1, 22.2, 22.3
and 22.4 to the separate financial statements,
while the accounting policies are described in
the explanatory notes to the separate financial
statements.
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.
Responsibilies of the Company’s Management and members of the Supervisory Board for the separate
financial statements
The Company’s Management is responsible for the preparaon of, based on properly maintained
accounng records, the separate financial statements that give a true and fair view of the property and
financial posion of the Company 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 legal regulaons applicable to the Company, as
well as the Company’s Statute, and is also responsible for such internal control as the Company’s
Management determines is necessary to enable the preparaon of the separate financial statements
that are free from material misstatement, whether due to fraud or error.
In preparing the separate financial statements, the Company's Management is responsible for
assessing the Company'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 Company’s
Management either intends to liquidate the Company or to cease operaons, or has no realisc
alternave but to do so.
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
The Company’s Management and members of the Company’s Supervisory Board are required to ensure
that the separate financial statements meet the requirements of the Accounng Act. The members of
the Company’s Supervisory Board are responsible for overseeing the Company’s financial reporng
process.
Auditor's responsibility for the audit of the separate financial statements
Our objecves are to obtain reasonable assurance about whether the separate financial statements as
a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s
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 separate financial statements.
The scope of the audit does not include assurance on the future profitability of the Company nor
efficiency or effecveness of conducng business maers now or in the future by the 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 separate 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 Company’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 Company’s Management;
conclude on the appropriateness of the 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 Company’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 auditor’s report to the related disclosures in the
separate financial statements or, if such disclosures are inadequate, to modify our opinion. Our
conclusions are based on the audit evidence obtained up to the date of our independent
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
auditor’s report, however, future events or condions may cause the Company to cease to
connue as a going concern;
evaluate the overall presentaon, structure and content of the separate financial statements,
including the disclosures, and whether the separate financial statements represent the
underlying transacons and events in a manner that achieves fair presentaon.
We communicate to the 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 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 Company’s Supervisory Board, we determine those maers
that were of most significance in the audit of the separate financial statements of the current period
and are therefore the key audit maers. We describe these maers in our auditor’s 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 Company Acvity Report
Other informaon
Other informaon comprises combined Group and Company Acvity Report as at 31 December 2025
(the ‘Company Acvity Report’) together with the representaon on applicaon of corporate
governance, which are separate elements of this Company 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 Company’s Management and members of the Supervisory Board
The Company’s Management is responsible for the preparaon of the Other informaon in accordance
with laws.
The Company’s Management and members of the Supervisory Board are required to ensure that the
Company Acvity Report with separate elements meets the requirements of the Accounng Act.
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
Auditor's responsibility
Our audit opinion on the separate financial statements does not include the Other informaon.
In connecon with the audit of the separate 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 separate 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
auditor’s 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 Company 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
separate financial statements. Moreover, we are required to issue an opinion on whether the Company
has included the required informaon in the representaon on applicaon of corporate governance.
We obtained the Company 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 Company's Supervisory Board.
Opinion on the Company Acvity Report
Based on the work performed during our audit, in our opinion, the Company Acvity Report:
has been prepared in accordance with the arcle 49 of the Accounng Act and paragraph 72
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 separate financial statements.
Statement on the Company Acvity Report
We cerfy that, based on our knowledge of the Company and its environment obtained during our
audit, we have not idenfied material misstatements in the Company Acvity Report.
Opinion on the corporate governance representaon
In our opinion, in the representaon on applicaon of corporate governance, the Company 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
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
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 separate financial statements.
Report on other legal and regulatory requirements
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 Company 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 Company and its
subsidiaries during the audited period are listed under “Provision of permied non-audit services by
the Auditor” of the Company Acvity Report.
Appointment of the audit firm
We were appointed for the audit of the Company’s separate financial statements based on the
resoluon of the Company’s Supervisory Board dated 25 January 2024. This is the eleventh year in
which we have conducted the audit of the Company’s financial statements, including the seventh year
during which the 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 separate 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 Auditor’s 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 Company’s internal purposes. In case of any discrepancies between
the Polish and English version, the Polish version shall prevail.
Warsaw, 30.03.2026