The Polish tax administration is gradually introducing the obligation to maintain and submit tax books electronically to the tax authorities in the JPK (Standard Audit File for Tax) format.
This change is part of the broader digitalization of the tax system and means that businesses will provide tax authorities with full accounting data in a standardized electronic format.
However, the new regulations do not come into force simultaneously for all companies. The obligation is being implemented in stages, depending on the size of the enterprise and its tax settlement model.
Table of contents:
- When does the obligation to submit tax books in JPK format come into force?
- Which JPK files will need to be submitted?
- When should tax books be sent to the tax office?
- Who is exempt from submitting electronic tax books?
- What do the new regulations mean for businesses?
When Does the Obligation to Submit Tax Books in JPK Format Come into Force?
The implementation schedule for the new regulations consists of three main phases.
1. Largest taxpayers – books for 2025
The first group covered by the obligation includes the largest enterprises.
For tax years starting after 31 December 2024, the obligation to maintain and submit electronic tax books will apply to capital groups and CIT taxpayers whose revenues exceeded EUR 50 million in the previous year.
In practice, this means that for the 2025 tax year, the largest companies will submit their books to the tax authorities for the first time in 2026. The deadline for submitting JPK_CIT is 31 July 2026.
2. Next group of companies – books for 2026
For tax years starting after 31 December 2025, the obligation will be extended to another group of businesses.
This applies to entities that settle VAT on a monthly basis and submit the JPK_V7M file.
At this stage, the obligation will cover not only accounting books but also other tax records, depending on the nature of the business activity.
3. All remaining companies – books for 2027
For tax years starting after 31 December 2026, the new regulations will apply to all remaining businesses, including those that settle VAT quarterly or are VAT-exempt.
This means that ultimately, nearly every business maintaining tax books will be required to keep them in an electronic system and submit them to the tax authorities in the JPK format.
Which JPK Files Will Be Submitted?
The type of JPK files to be submitted depends on the accounting model used by the business.
Entities maintaining full accounting records (CIT)
Entities keeping full accounting books will be required to submit, among others,
- JPK_KR_PD (accounting books for tax purposes)
- JPK_ST_KR (fixed assets register)
It is important to note that for certain periods, the legislator has introduced a temporary exemption from submitting the fixed assets file. The largest entities are not required to submit JPK_ST_KR for 2025; this obligation will apply from 2026.
Taxpayers maintaining a tax revenue and expense ledger (PKPiR)
Entities using the PKPiR system will submit JPK_PKPIR (tax revenue and expense ledger) and JPK_ST (fixed assets register).
Taxpayers under lump-sum taxation (flat-rate)
In the case of lump-sum taxation on recorded revenues, the obligation will include submitting JPK_EWP (revenue register) and JPK_ST (fixed assets register).
Taxpayers under lump-sum taxation
In the case of lump-sum taxation on recorded revenues, the obligation will include:
- JPK_EWP (revenue register)
- JPK_ST (fixed assets register)
When Should Tax Books Be Submitted to the Tax Office?
Tax books will be submitted once a year, after the end of the tax year.
The submission deadline is aligned with the deadline for filing the annual tax return (e.g. CIT-8 or PIT).
In practice, this means that businesses will submit electronic tax books together with their annual income tax return. It should also be noted that the deadline for submitting JPK_CIT for the largest taxpayers for the 2025 tax year has been extended from 31 March 2026 to 31 July 2026.
Who Is Exempt from Submitting Electronic Tax Books?
The legislator has provided for several exemptions. The obligation to submit tax books in the JPK structure does not apply, among others:
- to certain entities exempt from CIT.
- taxpayers maintaining simplified revenue and cost records.
- selected foreign permanent establishments operating under simplified tax accounting.
What Do the New Regulations Mean for Businesses?
The new regulations represent a significant shift in the relationship between businesses and the tax administration.
Tax authorities will gain access to detailed accounting data in a standardized digital format, enabling automated data analysis and faster detection of irregularities.
As a result, for many companies it will be essential to adapt accounting and ERP systems to the new JPK structures, ensure proper mapping of accounting data, and streamline tax reporting processes.
In practice, preparations for these new obligations should begin well in advance, particularly in organizations with large-scale operations and complex accounting structures.
