Polish statutory reporting · JPK_CIT
Poland's SAF-T is a national schema, and it is not the OECD one.
If your Polish entity is in scope, it files its accounting books and its fixed-asset register as XML to the Ministry of Finance's gateway, on a schema the Ministry publishes and revises itself. A SAF-T export from a group ERP does not satisfy that obligation, however good the export is. This page settles the vocabulary, then answers the two questions a group actually needs answered: is the Polish entity in scope, and by when.
The vocabulary, settled first
Six terms carry most of the confusion in a first conversation with a Polish adviser. None of them translates cleanly, and two of them are false friends.
- SAF-T / JPK
- Poland calls its standard audit files JPK — Jednolity Plik Kontrolny. They are commonly described as SAF-T, and the family resemblance is real, but the schemas are national ones published by the Polish Ministry of Finance. An OECD SAF-T export does not satisfy them and cannot be mapped into them mechanically.
- JPK_CIT
- A colloquial umbrella name, not a schema. The Ministry publishes two structures under it: JPK_KR_PD for the accounting books, and JPK_ST_KR for the fixed-asset and intangible-asset register. A company in scope files both, on the same deadline.
- UPO
- Urzędowe Poświadczenie Odbioru — the official confirmation that the gateway accepted a filing. It is the document an audit asks to see. We leave the term untranslated on purpose: inventing an English word for it makes the evidence harder to recognise, not easier.
- CIT-8
- The annual corporate income tax return. JPK_CIT does not replace it and does not change it. They are two separate obligations with two separate deadlines, and conflating them is the most common planning error we see.
- UPL-1
- The power of attorney for signing documents filed electronically. Who is entitled to submit is a condition entirely separate from whether the file is well formed — a schema-valid file is still rejected when the authorisation is not in place.
- XSD validation
- Checking the generated XML against the Ministry’s published schema before it is submitted. It proves the structure conforms. It proves nothing about the gateway’s decision, which also depends on authorisation.
Why the statements below are in Polish
Each block that follows is quoted in the wording of its primary source — the statute, the official journal, or the Ministry's own brochure — with a link and the date a person last opened it. We do not translate a statutory sentence and then cite the translation as though it were the source. The English text around each block tells you what it means; the block itself is what your Polish adviser will recognise.
Who is in scope, and from when
The obligation phases in over three waves. What decides your wave is not a calendar date but the tax year — the financial year, for entities that are not legal persons — and specifically the day that year begins. For an entity on a non-calendar year that distinction changes the answer, so it is worth checking before anything else.
Wave one covered tax capital groups and taxpayers above a revenue threshold the statute expresses as a euro equivalent; those filings have already been made. Wave two covers taxpayers who file monthly VAT records — in practice, most trading and manufacturing entities, and the largest group by number. Wave three covers everyone else. Membership of a tax capital group puts an entity in wave one on its own, with no revenue test at all.
The obligation to submit JPK_KR_PD takes effect in three waves, by the tax year (or, for companies that are not legal persons, the financial year) beginning after: 31 December 2024 — tax capital groups (PGK) and taxpayers with revenue above the equivalent of 50 million euro; 31 December 2025 — taxpayers required to submit JPK_V7M files; 31 December 2026 — all remaining taxpayers, including those filing JPK_V7K.
For PIT taxpayers who keep accounting books the waves are shifted by one year — the two schedules must not be mixed.
Verified 6 August 2026 · Ministerstwo Finansów, Aktualizacja broszury informacyjnej JPK_KR_PD(1) – aktualna od 01.07.2026 r.
The Polish text of the linked source is authoritative.
Tax capital groups (PGK) are covered by the first JPK_CIT wave regardless of the level of their revenue — the 50 million euro threshold is a separate, alternative condition.
Verified 6 August 2026 · Ustawa z 26.05.2023 (Dz.U. 2023 poz. 1059) – art. 66 ust. 2 pkt 1 lit. a ustawy z 29.10.2021
The Polish text of the linked source is authoritative.
Exempt from the obligation to file JPK_KR_PD and JPK_ST_KR are: taxpayers with a personal exemption from tax (with the exception of family foundations), taxpayers entitled to file their return on paper, and those keeping a simplified record of revenue and costs.
Family foundations are an exception to the personal exemption.
Verified 6 August 2026 · Ministerstwo Finansów, Aktualizacja broszury informacyjnej JPK_KR_PD(1) – aktualna od 01.07.2026 r.
The Polish text of the linked source is authoritative.
The deadline is a rule, not a fixed date
For corporate income tax the statutory deadline runs from the end of the tax year, so an entity on a non-calendar year has a different date from its calendar-year sister company. A separate regulation extended the deadline for one narrow, closed range of years; outside that range the statutory rule applies. Personal income tax taxpayers are governed by a different rule again, and the two are routinely conflated in commercial commentary.
CIT taxpayers submit their accounting books in JPK form by the end of the seventh month after the end of the tax year. The deadline for filing the CIT-8 return is unchanged — these are two separate obligations.
Verified 6 August 2026 · Ustawa z 15.05.2026 o zmianie ustawy o PIT, ustawy o CIT oraz ustawy o zryczałtowanym podatku dochodowym (Dz.U. 2026 poz. 779), art. 2 pkt 1 lit. a i b
The Polish text of the linked source is authoritative.
Corporate income tax taxpayers in wave two — those whose tax year begins after 31 December 2025 — file JPK_KR_PD for that year by the end of the seventh month after it ends; for calendar year 2026 that means 31 July 2027.
The date 31 July 2027 is that rule worked out for a calendar year, not a separate communiqué from the Ministry.
Verified 6 August 2026 · Ministerstwo Finansów, Aktualizacja broszury informacyjnej JPK_KR_PD(1) – aktualna od 01.07.2026 r., sekcja „Terminy przesyłania pliku JPK_KR_PD”
The Polish text of the linked source is authoritative.
The first year for which first-wave CIT taxpayers actually submit JPK_ST_KR is the tax year beginning on 1 January 2026 or later — for a calendar year, that is 2026.
Verified 6 August 2026 · Ministerstwo Finansów, Aktualizacja broszury informacyjnej JPK_ST_KR(1) – aktualna od 01.07.2026 r.
The Polish text of the linked source is authoritative.
Note the asymmetry between the two structures. The fixed-asset register was not filed in the first year because it was exempted, so an entity that has already filed once has still never filed JPK_ST_KR. The data it needs had to be collected from the start of the reporting year and cannot be reconstructed afterwards.
What is genuinely hard about it
Not the schema. The schema is published, documented and finite. The difficulty sits before it, and it is the same in every group we have looked at.
Getting the data out
The structures want data in a shape a finance system rarely holds in one place. Part sits in the ledger, part in the asset register, part in whatever spreadsheet closes the period. A group instance does not make this easier — it usually makes the Polish subset harder to isolate.
Several entities, one deadline
One entity is a task. A dozen — some on a different system, some acquired, one on something nobody maintains — is a scheduling problem. Every entity is a separate file, a separate authorisation to submit, and a separate UPO to keep.
Authorisation is a separate gate
Whether the file is well formed and whether the person submitting it may do so are two independent conditions. A structurally correct file is still refused when the power of attorney is not in place, which is why nothing on this site describes the gateway's answer in advance.
What SimplyTax does about it
SimplyTax is not an accounting system and writes nothing back to yours. It takes what the Polish entity's system can already hand over, builds JPK_KR_PD and JPK_ST_KR from it, shows the XML, and validates against the Ministry's official XSD before anything is sent. The whole cycle — submission, reference number, status polling, UPO — can be rehearsed on the Ministry's test gateway first, on a closed period, so the first live filing is not the first filing.
Afterwards the file carries its own evidence: status, reference number and the downloaded UPO, archived per period and per entity, with a company switcher for groups. The interface is Polish and English. Deployment is cloud or on-premise in your own environment, and both are genuinely delivered rather than announced.
There is no list of supported ERPs, deliberately. The translator is written for the source system, so a group with two hundred sites on one ERP still needs one translator — it reads from one source. If we do not support your system yet, we write one; if we do, you arrive to something that already exists.
XSD validation proves conformity with the schema and nothing beyond it. Acceptance also depends on who is entitled to submit, which is why the two stages are shown separately rather than promised as an outcome.
When you probably do not need us
If your system vendor ships a working JPK module, or the system exports everything the structure needs, the Ministry's free Klient JPK_WEB will most likely do. It validates, signs and submits, and we are not going to pretend otherwise. The conversation starts making sense when the system is non-standard: no module, an export missing what the structure requires, or data assembled from more than one source. The number of entities is not the criterion — a single Polish company on an awkward system is a normal customer, not an exception.
This page describes Polish reporting obligations and cites their primary sources. It is not tax advice, and whether a specific rule applies to a specific entity is a question for your Polish adviser rather than for a software vendor.
Field-level detail on each structure exists only in Polish:JPK_KR_PD,JPK_ST_KR.
Let's check it against one of your files
The fastest way to find out how much work is ahead is to take what the Polish entity's system can export today and see what the structure is missing. Thirty minutes with the people who file these, in English or Polish, and no presentation.
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