The legal framework of SAF-T in Poland
The Poland SAF-T framework consists of eight JPK structures:
Poland SAF-T framework
Poland is one of many countries to use the Standard Audit File for Tax (SAF-T) to streamline tax compliance and reporting for businesses. The country was one of the first in Europe to replace the traditional VAT return with SAF-T.
Poland introduced its version of SAF-T, known as Jednolity Plik Kontrolny (JPK), in 2016, making monthly submissions of JPK_VAT compulsory for all taxpayers in 2018.
In 2020, JPK_VAT combined with the VAT return and is submitted with a declaration per the frequency of the VAT Return (monthly or quarterly).
Submission of the remaining seven JPK structures is upon request of the tax authority in the event of an audit.
Please note: JPK_VAT with the declaration is in the process of changing as a result of the introduction of mandatory e-invoicing via KSeF in Poland.
JPK_V7M/K
declaration for records of VAT purchases and sales combined
JPK_FA
for VAT and VAT invoices
JPK_WB
for bank statements
JPK_PKPIR
for revenue and expense ledger
JPK_EWP
for revenue account
JPK_KR
for accounting books
JPK_MAG
for warehouses
JPK_FA_RR
for flat rate VAT invoices
Other than the monthly or quarterly periodic submission of JPK_V7M/K, submission of all other JPK structures is on demand.
However, from 1 January 2025, reporting of JPK EWP, JPW PKPIR, and JPK_KR will become a periodic reporting obligation.
Timeline SAF-T in Poland
- 1 July 2016: SAF-T introduced in Poland in the form of JPK files
- 1 January 2018: Poland mandated JPK_VAT for all taxable persons
- 1 July 2018: Taxpayers must be able to produce accounting documents in JPK structures
- 1 October 2020: JPK_VAT with declaration consolidates the VAT Return and JPK_V7M/K
- 1 July 2021: Amendments to the mandatory JPK_V7M/K adopted
- 1 January 2022: Amendments to the JPK_V7M/K structure including changes to better align it with the EU VAT e-Commerce package
- 1 January 2025: Reporting of JPK EWP, JPW PKPIR, and JPK_KR becomes a periodic obligation
Understanding JPK VAT and SAF-T in Poland
One of the eight JPK structures in Poland is JPK_VAT, a declaration combining VAT purchase and sales records. As of 2020, JPK_VAT must be sent alongside VAT returns to the tax authority.
JPK_VAT with the declaration has two variants, depending on the submission frequency of the VAT return:
- JPK_V7M for taxpayers settling VAT monthly.
- JPK_V7K for taxpayers who settle VAT quarterly.
Submission of JPK_V7M and JPK_V7K is on the 25th of the month following the reporting period.
The other SAF-T JPK structures for VAT are JPK_FA for VAT invoices and JPK_FA_RR for flat-rate VAT invoices. JPK_FA and JPK_FA_RR are both submitted on demand.
Implementing SAF-T as a business
SAF-T requires additional data to analyse and authenticate the accuracy of documentation. All data submitted in the SAF-T consolidated submission must be accurate and complete to ensure compliance.
Data for SAF-T requirements is often extracted from multiple sources for a single report and combining this data can be difficult.
The data required for SAF-T differs significantly from other reporting obligations that businesses might be familiar with. The XML format required for reports makes it difficult to review, compare or test reports ahead of submissions.
Other requirements for VAT compliance in Poland
As well as Poland’s SAF-T requirements, taxpayers need to also be aware of the KSeF e-invoicing mandate. Poland’s continuous transaction control (CTC) e-invoicing system is mandatory as of 1 July 2024, expanding to VAT-exempt taxpayers in 2025. Read this overview for a general introduction to Poland VAT compliance.
FAQ
What is JPK_VAT?
JPK_VAT with a declaration is an electronic document that includes both VAT records, combining information on purchases and sales and VAT returns (VAT-7M and VAT-7K).
When to submit JPK_VAT in Poland?
JPK_VAT is submitted on a monthly or quarterly basis.
Is SAF-T mandatory in Poland?
Yes, SAF-T is mandatory in Poland. JPK VAT with a declaration must be sent to the tax authority on a periodic basis, while other types of JPKs are sent on demand.
What are the penalties for non-compliance with SAF-T in Poland?
Failure to comply with the SAF-T requirements in Poland can lead to penal and fiscal sanctions, based on a misdemeanor or a felony. If the value of the reduction of the tax liability exceeds PLN 10,000, it is a crime.
What are the submission deadlines for SAF-T in Poland?
Submission of JPK_VAT with the declaration (JPK_V7M and JPK_V7K) is on the 25th day of the month following the reporting period. Other JPKs are submitted to tax authorities within three days after receiving a request from the tax authority.
Our Solution capabilities for Poland SAF-T
Data Extraction
Painlessly aggregate and consolidate data from a wide range of source systems complying with Poland’s SAF-T requirements including JPK files.
Data Analytics
Check the accuracy, integrity and quality of complex data structures required by Poland SAF-T to give you peace of mind before you submit your JPK files to the tax authority.
File Generation
Ensure that all required data sets from accounting entries, sales and purchase transactions, asset depreciation, stock movements and more, are mapped seamlessly into Poland’s JPK schema, ready to be analyzed and submitted to the tax authority.
