The Polish Ministry of Finance has published errata to the informational brochures for JPK_KR_PD (Accounting Books) and JPK_ST_KR (Fixed Assets Records) structures. They clarify the taxpayer categories for the phased implementation of these reporting obligations.
The key clarification specifies that the second implementation wave applies to taxpayers obliged to submit JPK_V7M files (monthly VAT filers), while the final wave explicitly includes taxpayers obliged to submit JPK_V7K files (quarterly VAT filers).
Although the deadlines itself remain unchanged, taxpayers should verify their VAT filing type (V7M vs V7K) to confirm which implementation wave applies to them.
The JPK_KR_PD and JPK_ST_KR structures will be mandatory from:
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1 January 2025: CIT taxpayers and companies that are not legal persons whose revenue obtained in the previous tax year (or in the case of companies that are not legal persons – the financial year) exceeded EUR 50 million, and tax capital groups.
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1 January 2026: CIT taxpayers and companies that are not legal persons and PIT taxpayers keeping accounting books, obliged to submit JPK_V7M files.
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1 January 2027: other CIT taxpayers and companies that are not legal persons and other PIT taxpayers keeping accounting books, including taxpayers obliged to submit the JPK_V7K file.
In 2024, the Ministry of Finance exempted CIT taxpayers and companies that are not legal persons from the obligation to submit the JPK_ST_KR structure for tax years beginning after 31 December 2024 and before 1 January 2026.
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