Poland has entered the next phase of its digital revolution in tax, bringing new electronic and digital reporting and invoicing obligations. First, the requirement to report all economic events affecting financial and tax results, as well as the recording of fixed assets, in the new electronic format has been introduced, commonly known as the JPK CIT. Second, mandatory e-invoicing is already certain to be introduced in 2026.
JPK CIT: scope of obligation
The largest taxpayers are required to automatically submit detailed income tax data to the tax authorities in a prescribed electronic form from 2025. From 2026, this obligation will apply to all taxpayers. The following information must be reported under the JPK_KR_PD schema:
All accounting entries (including cost and revenue invoices with contractor identification);
All accounting accounts with official designations (which, de facto, allows for the identification of the nature of each account);
Accounts involving transactions with related entities;
Accounts with costs settled according to the rules for R&D tax relief and the IP Box (under which, qualifying income from eligible intellectual property is taxed at a preferential rate);
Accounts with costs that are not tax deductible; and
Data affecting the difference between the tax and financial results.
Moreover, the JPK_ST_KR schema will require reporting a wide range of data on fixed assets, including information on their disposal or liquidation. In practice, this scope is broader than that typically included in fixed asset records.
Reporting will be carried out once a year, on the due date for filing the corporate income tax return; i.e., three months after the year end. The files can be enormous. Work is under way to prepare the tax authorities’ IT systems.
JPK CIT: how to prepare?
It is crucial to upgrade existing accounting systems, which will allow them to generate XML files for official delivery. If this is not possible, an analysis should be conducted to determine how the system extract can be converted into the required file.
Regardless of the technological aspect, every taxpayer must review its chart of accounts and assess whether changes are necessary to comply with the JPK CIT requirements. Mapping accounts with tags, including those related to the transition to the tax result, is often a significant challenge. Certain elements of accounting policy and cost accounting practices may also change. Sometimes, meeting substantive requirements requires seeking non-standard solutions, which require collaboration between a tax adviser and the system provider.
JPK CIT: a new look at the taxpayer–tax authority relationship
The new obligation is revolutionary because, in practice, it means that tax authorities will have access to a very wide and detailed range of data. Until now, obtaining this data required initiating a formal tax audit. In the coming years, the tax authorities can be expected to expand their capabilities in data analysis, comparison, and the selection of taxpayers or transactions for audit. Dedicated software or AI solutions will likely be used for this purpose.
Taxpayers will lose significant flexibility in terms of settlement adjustments and the technical aspects of tax calculations. On the other hand, this could also be an opportunity to automate processes; for example, in the preparation of tax returns.
Mandatory e-invoicing coming soon
The new e-invoicing obligations will create a large database for the tax authorities, allowing them – together with JPK CIT and JPK VAT (VAT SAF-T) – to automate verification of tax settlements.
The finally adopted amendments to the Polish VAT Act introduce an obligation to issue invoices in a standardised XSD format through a governmental clearing system (the local abbreviation KSeF is often used, which comes from the Polish name for National System of e-Invoices). The implementation will occur in three phases:
From February 2026 for the largest taxpayers, with gross turnover exceeding PLN 200 million;
From April 2026 for taxpayers below the above threshold, with the exception of small enterprises whose monthly turnover does not exceed PLN 10,000; and
From January 2027 for small enterprises.
Although e-invoicing in KSeF will be introduced in three phases, it is important to note that the receipt of e-invoices will be obligatory for all taxpayers starting from February 1 2026. However, one positive is that the sanctions for non-compliance with KSeF are postponed until January 1 2027.
The legislative process has not been finalised, since a number of implementing regulations are still missing. With only four months before the invoicing revolution, there may not be sufficient time to ensure that all the necessary modifications are implemented in the taxpayers’ IT programs and business processes. Many issues are not clear and the tax authorities’ guidelines are needed.
Implementing KSeF is a complex and time-consuming process. It involves not only technical aspects but also the inevitability of making very significant changes to processes, internal procedures, contracts, and regulations.
