Author:
Jarosław Ziółkowski,
Tax Adviser, Manager
Independent Tax Advisers Doradztwo Podatkowe Sp. z o.o.
E: [email protected]
W: https://itadp.pl/
Edited by:
Integra International
Grant Gilmour, B.Sc., MBA, CA, CPA Canada, BC, CPA USA, Az, GDipICL.Sc.
INTEGRA TAX WORLD NEWSLETTER EDITOR
E: [email protected]
Polish Taxation Moves Toward Full Online Reporting
Accounting Books Sent as Obligatory SAF‑T
The modern Polish tax administration is entering a new stage of digitization, which fundamentally changes the relationship between the taxpayer and the tax authorities. The key tool of this transformation is the so-called JPK_CIT, [i]i.e. the statutory obligation to periodically send accounting books and fixed asset records in a standardized electronic form. From the point of view of those responsible for tax settlements, this is not just another technical change, but a profound reform of the reporting philosophy. It requires businesses to be fully transparent about their data in near real-time, while giving tax authorities insight into the financial life of a business.
From JPK_KRi on demand to mandatory JPK_CIT
In recent years, the JPK_KR file has functioned mainly as an audit tool, provided only at the express request of the tax authorities in the course of audits or verification activities. This model was based on reactivity – the tax office analyzed the data only after there was a suspicion of irregularities. The introduction of JPK_CIT reverses this pattern. According to the new regulations, taxpayers who keep accounting books using computer programs are obliged to send them periodically without being summoned by the authority. This means the transformation of the file from a control to a reporting nature, which is a close analogy to the JPK_VAT mechanism concerning the value added tax. The tax authority gains constant insight into accounting records, which enables automatic analytics, precise selection for inspection and verification of settlements without the physical presence of auditors at the company’s headquarters.
Structures JPK_KR_PD and JPK_ST_KR
The new reporting model is based on two separate logical structures that together create an accounting and tax picture of the entity.
JPK_KR_PD (accounting books)
The JPK_KR_PD structure is a significantly extended version of the existing JPK_KR file. It contains, among others, the following elements (nodes):
- Contractor: a node containing the system identification numbers and NIP (Numer Identyfikacji Podatkowej, tax identity number) of contractors;
- ZOiS (Zestawienie Obrotów i Sald, Statement of Turnover and Balances): a detailed list of accounts with assigned tags;
- Journal and Account Record: chronological record of economic events with an automatically assigned item number;
- RPD (Rozliczenie Podatku Dochodowego, Income Tax Settlement): a new node in which the differences between the accounting result and the tax base are shown (exempt revenues, non-KUP costs, temporary and permanent differences).
JPK_ST_KR (fixed assets)
It is a completely new structure dedicated to the records of fixed assets and intangible assets. Its purpose is to agree on depreciation in the accounting and tax dimensions. It includes fields such as:
- Acquisition/production data, document numbers (OT) and inventory numbers;
- Depreciation method (e.g. straight, degressive) and depreciation rates;
- Initial values (tax and accounting) and depreciation write-offs;
- KSeF (Krajowy System e-Faktur, The National System of e-Invoices) numbers of invoices documenting the sale of an asset.
Implementation schedule
The obligation is implemented in stages, with the status of the taxpayer and the amount of its tax revenues being decisive. The schedule for the introduction of JPK_CIT is presented in the table below.
[i] „JPK” is a name of the Polish SAF-T, which comes from „Jednolity Plik Kontrolny”. „KR” comes from „księgi rachunkowe” (accounting books), „ST” comes from „środki trwałe” (fixed assets) and CIT is corporate income tax. These names are actually technical names of the SAF-Ts.
| Since when? | Who does it concern? | Exclusions |
| tax year starting after 31 December 2024 | tax capital groups and the largest entities whose revenue exceeded EUR 50 million | For the first tax year, it is not necessary, among other things, to fill in the RPD node in the JPK_KR_PD and to prepare the JPK_ST_KR |
| tax year starting after 31 December 2025 | CIT Corporate Income Taxpayers obliged to send VAT records every month (submitting JPK_V7M ). | No exclusions |
| tax year starting after 31 December 2026 | other CIT taxpayers | No exclusions |
It should be added that the Polish Ministry of Finance plans to issue a regulation that will exempt all taxpayers from the obligation to prepare JPK_ST_KR for the years 2026 – 2028. At the moment, the final wording of this regulation has not been published.
It should also be mentioned that similar obligations regarding the electronic submission of books also apply to natural persons, both those who keep accounting books and simplified tax records.
Submission deadlines and formal aspects
Normally, JPK_CIT files are uploaded once a year, by the end of the seventh month after the end of the tax year (i.e. after the approval of the financial statements). Therefore, for the largest taxpayers whose tax year is a calendar year, the deadline for filing a file for 2025 is July 31, 2026. The files must be provided with a qualified electronic signature and sent to the relevant tax office by a person who has been granted a power of attorney to sign electronic declarations electronically (UPL-1). For the time being, file transfer will not replace the standard annual CIT-8 return.
Practical implementation challenges
Account mapping
Taxpayers must assign each accounting account from the company chart of accounts a tag from the dictionary contained in the Regulation of the Minister of Finance of 16 August 2024. For most units, the dictionary from Annex 7 of this Regulation will apply. Nevertheless, taxpayers preparing financial statements in accordance with International Accounting Standards, International Financial Reporting Standards and related interpretations published in the form of regulations of the European Commission may not supplement the books of accounts for the tax year beginning after 31 December 2024 and before 1 January 2028 with tags identifying the accounts of the ledgers.
Elimination of the so-called “bag accounts”
The Polish Ministry of Finance assumes that a given account is entirely either tax or non-tax. The existence of the so-called bag accounts, where costs constituting and non-tax-deductible costs (for example, the costs of representation, part of the expenditure related to the acquisition and operation of passenger cars or sanction payments) are posted at the same time, will make it impossible to correctly assign tags. It is necessary to analytically separate such accounts at the ERP system level.
Reconciliation of the RPD node with the tax note
The RPD node is not a mirror image of the CIT-8 declaration, which contains extensive data, such as losses from previous years or reliefs. The values in the RPD should first be identical to the tax note in the financial statements.
Summary
The introduction of JPK_CIT is a turning point that will further improve the analytics of the tax administration. Tax authorities are gaining a tool for automatic checking and processing of data from various declarations submitted electronically (SAF-T Standard Audit File for Tax for value added tax – JPK_V7 files, the discussed files reflecting accounting books, TPR-C information on transfer pricing) or from the recently functioning National e-Invoicing System (KSeF). For example, the sale of a fixed asset reported in the JPK_ST_KR must be reflected in the KSeF and the JPK_V7 file, otherwise an alert about irregularities will be generated immediately. For the taxpayer, this is a signal to modernize ERP systems and seal internal control procedures. It should be clearly emphasized: JPK_CIT is not only a new reporting obligation, but a complete change in the philosophy of bookkeeping in Poland and making data available to the tax administration. A proper and timely implementation process will avoid the risks associated with incorrect file preparation and ensure tax security in the new, fully digital reality.
Disclaimer
This communication contains general information only based on collective research. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No representations, warranties or undertakings (express or implied) are given as to the accuracy or completeness of the information in this communication, and none of Independent Tax Advisers Doradztwo Podatkowe Sp. z o.o., Integra International, related entities, employees or agents shall be liable or responsible for any loss or damage whatsoever arising directly or indirectly in connection with any person relying on this communication.
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© 2026 Integra and Independent Tax Advisers Doradztwo Podatkowe Sp. z o.o.
[1] „JPK” is a name of the Polish SAF-T, which comes from „Jednolity Plik Kontrolny”. „KR” comes from „księgi rachunkowe” (accounting books), „ST” comes from „środki trwałe” (fixed assets) and CIT is corporate income tax. These names are actually technical names of the SAF-Ts.
About the Author:
Jarosław Ziółkowski
Tax adviser, Manager
Our firm has been operating in the market since February 2004. ITA Doradztwo Podatkowe offers an individual approach to tax aspects of each of its Clients. We concentrate on dynamic growth of our firm and on ensuring the highest quality of services guaranteed by a fully independent tax advisory firm.
We provide services to large international businesses, Polish companies and to small- and medium-sized entrepreneurs looking for assistance in developing their newly incorporated undertakings. We assist our Clients in every step of their activity and growth. We advise them on planned and performed transformations, mergers and acquisitions, as well as in the process of liquidation of economic entities.
We offer our Clients comprehensive tax advisory services. We have established specialisation teams supervised by our experienced tax experts. We have an individual approach to each Client and matter in which we are involved. Thanks to our consultants’ experience we can look at tax issues from the broadest possible perspective.
Members of the team of INDEPENDENT TAX ADVISERS Doradztwo Podatkowe Sp. z o.o. are tax advisers and experienced consultants who have gained their professional know-how in well-known advisory firms of the so-called Big Four. Our specialists are recognised authors of numerous professional publications. Our team members provide tax training and are invited to participate in numerous conferences in Poland and abroad.
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