For most businesses, the financial year is the same as the calendar year. Entities that keep accounting books (full accounting) prepare their annual financial statements after the financial year has closed – the statements for 2025 are prepared in 2026. The process needs particular care because of the requirements on electronic form and the new logical structures published by the Ministry of Finance. Preparing the statements in the Ministry’s logical structure is part of our bookkeeping services.
Electronic financial statements for 2025 are governed by strict legal rules covering not only the preparation deadline but also the file format, the signing method and the approval and filing procedures. Knowing these requirements is essential for entities entered in the KRS (National Court Register) to meet their reporting obligations correctly.
Deadlines for preparing the financial statements for 2025
Under the Accounting Act, financial statements are prepared as at the day the accounting books are closed. Entities whose financial year is the same as the calendar year must prepare their financial statements for 2025 by 31 March 2026. This deadline follows from Article 52 section 1 of the Accounting Act, which states that the head of the entity ensures the annual financial statements are prepared no later than within 3 months of the balance sheet date.
Accounting books are closed as at the last day of the financial year, but no later than within 3 months of that day. For entities whose financial year is the calendar year, this means closing the books for 2025 by 31 March 2026 (Article 12 section 2 point 1 of the Accounting Act). Failure to meet this deadline may lead to legal sanctions and complications in the reporting process
Preparing the financial statements requires source documents to be ready in advance and a stocktake (inventory) of assets and liabilities to be carried out. Entities should start these preparations as early as December of the financial year to make sure the statements are prepared on time and in line with legal requirements.
Financial statements are prepared using the rules for valuing assets and liabilities and determining the financial result set out in Chapter 4 of the Accounting Act. All business transactions must be properly documented and reflected in the accounting books before the statements are prepared
The head of the entity is personally responsible for ensuring that the financial statements are prepared on time and comply with the Accounting Act. This requires proper supervision of the accounting process and cooperation with the people responsible for keeping the books.
Electronic format of the financial statements
The regulations clearly state that the financial statements for 2025 must be prepared only in electronic form. Under Article 45 section 1f of the Accounting Act, statements cannot be prepared on paper. Every set of financial statements must be signed with a qualified electronic signature, a trusted signature (podpis zaufany) or a personal signature (podpis osobisty).
Electronic financial statements must be prepared as a file that can be saved and read with a computer program. The file must be signed digitally with one of the three permitted types of electronic signature. Without a proper electronic signature the statements cannot be filed
The financial statements of entities entered in the KRS register of entrepreneurs must be prepared in the logical structure and format published by the Ministry of Finance. These structures are published in the Public Information Bulletin (BIP) on the website of the office serving the minister responsible for public finance (Article 45 section 1g of the Accounting Act). The same structure is used by CIT (corporate income tax) payers outside the KRS register of entrepreneurs, who send the statements to the head of KAS (National Revenue Administration) within 15 days of approval (Article 27 section 2 of the CIT Act), and by individuals keeping accounting books – before the deadline for filing the PIT (personal income tax) return (Article 45 section 5 of the PIT Act).
XML is the basis of electronic financial statements. It is a type of text file containing structured data described by tags. The statements should be produced as a single XML file containing all required elements (in entities other than micro and small entities, also the statement of changes in equity and the cash flow statement – Article 45 section 3):
- The entity's balance sheet
- Profit and loss account
- Notes to the financial statements
The XML file must comply with the XSD schema describing the data structure of the financial statements. The Ministry of Finance publishes the current logical structures on the e-Sprawozdania structures page (Struktury e-Sprawozdań). A file generated in breach of the published structures will not be accepted by the system
The new logical structures for financial statements were introduced as part of the modernisation of the e-Sprawozdania system. The changes reflect the need to adapt to business conditions and to the legal framework of the electronic financial reporting system.
New logical structures for statements for 2025
For statements for financial years starting on or after 1 January 2024, the Ministry of Finance published version v1-2 of the structures – the changes mainly concerned the description of profit and loss account items (some items were removed), following the new wording of Annexes 1, 4 and 5 to the Accounting Act (Dz.U. 2024 poz. 1863). In 2025, further versions of the structures, marked "(2)", were published in the Central Repository of Electronic Document Templates (CRWDE); they apply to financial statements prepared from 1 January 2026 – in practice, to statements for 2025. The successive stages of the work are set out in our guide on how to prepare financial statements step by step.
For other, micro and small entities, these are the following templates (the v1-2 equivalent in brackets):
- SFJINT(2) – other entities, figures in thousands of złoty (JednostkaInnaWTysiacach(1)_v1-2.xsd)
- SFJINZ(2) – other entities, figures in złoty (JednostkaInnaWZlotych(1)_v1-2.xsd)
- SFJMIT(2) – micro entities, figures in thousands of złoty (JednostkaMikroWTysiacach(1)_v1-2.xsd)
- SFJMIZ(2) – micro entities, figures in złoty (JednostkaMikroWZlotych(1)_v1-2.xsd)
- SFJMAT(2) – small entities, figures in thousands of złoty (JednostkaMalaWTysiacach(1)_v1-2.xsd)
- SFJMAZ(2) – small entities, figures in złoty (JednostkaMalaWZlotych(1)_v1-2.xsd)
Entities must adapt their accounting systems to the current templates before preparing the statements for 2025. After the transition period ended in 2026, the Ministry of Finance's e-Sprawozdania Finansowe application (statements sent to the head of KAS) does not accept statements prepared under the old structures, regardless of when they were prepared. Statements filed with the KRS go to the Financial Documents Repository run by the Minister of Justice
For the schemas JednostkaOpWTysiacach(1)_v1-2.xsd and JednostkaOpWZlotych(1)_v1-2.xsd, the v1-2 changes mattered only where the entity prepared its profit and loss account under Annex 1 to the Accounting Act. For statements prepared from 1 January 2026, entities referred to in Article 3 section 2 of the Act on public benefit activity and volunteering use the new templates SFJOPT(2) and SFJOPZ(2).
| Entity type | XSD schema | Main changes | Effect on the statements |
|---|---|---|---|
| Small entity | SFJMAZ(2) / SFJMAT(2) | Profit and loss account changes (since v1-2), new version (2) | Direct |
| Micro entity | SFJMIZ(2) / SFJMIT(2) | Profit and loss account changes (since v1-2), new version (2) | Direct |
| Other entity | SFJINZ(2) / SFJINT(2) | Profit and loss account changes (since v1-2), new version (2) | Direct |
| Non-governmental organisation (Article 3 section 2 of the public benefit act) | SFJOPZ(2) / SFJOPT(2) | New version (2); v1-2 profit and loss changes conditional | Profit and loss changes when using Annex 1 |
Signing the financial statements
Signing the annual financial statements for 2025 is a key step in the reporting process and must take place after the statements are prepared, but no later than 31 March 2026. Under Article 52 section 2 of the Accounting Act, the financial statements are signed by specified persons, who also give the date of signing.
The obligation to sign the financial statements lies with:
- The person entrusted with keeping the accounting books
- The head of the entity or all members of the multi-person body managing the entity
- Alternatively, at least one member of the multi-person body – after the other members have submitted statements (Article 52 section 2b)
Signing the financial statements is formal confirmation that they meet all the requirements of the Accounting Act (Article 52 section 2a). Allowing the statements to be prepared in breach of the Act or to contain unreliable data carries criminal liability (Article 77 point 2)
If any of the authorised persons refuses to sign the financial statements, that person must prepare a written justification, which must be attached to the statements. The refusal is prepared in electronic form with a qualified electronic signature, a trusted signature or a personal signature, or on paper with a handwritten signature (Article 52 section 2d). A refusal to sign does not stop the reporting process, but it must be properly documented.
A trading limited liability company prepared its financial statements for 2025. One member of its two-person management board refused to sign the statements because of doubts about inventory valuation. He prepared a written justification of the refusal, which was attached to the financial statements and filed with them in the court register (Article 69 section 3a).
The financial statements must also be accompanied by a statement confirming that they comply with the Accounting Act, or a refusal to make such a statement. In entities managed by a multi-person body, the statements may be signed by at least one person after the other members have made the relevant statements.
If the entity is managed by a multi-person body, the other members who do not sign the statements must submit statements that the financial statements meet the requirements of the Act. A refusal to submit such a statement is equivalent to a refusal to sign and requires a written justification
Approving and filing the financial statements
Approval of the annual financial statements for 2025 by the competent approving body is the next step in the reporting process. Under Article 53 section 1 of the Accounting Act, approval should take place no later than 6 months after the balance sheet date, i.e. by 30 June 2026.
The approval process differs depending on the legal form of the entity:
- In limited liability companies (sp. z o.o.), the statements are approved by the shareholders' meeting
- In joint-stock companies (spółka akcyjna), this role is performed by the ordinary general meeting of shareholders
- In state entities, the approving body is the competent founding body
- In associations and foundations, the statements are approved by the body named in the statute (for example the general meeting of members, the foundation council or the management board). A family foundation follows separate rules, which we cover in accounting books in a family foundation.
The final closing of the accounting books of an entity continuing its activity should take place no later than within 15 days of the date on which the financial statements for the financial year are approved (Article 12 section 4). The Act does not provide for extending this deadline
The annual financial statements, together with the required documents, are filed with the competent court register within 15 days of the date of approval. Under Article 69 section 1 of the Accounting Act, the head of the entity files the following documents:
- The annual financial statements
- The audit report, if the statements were audited
- A copy of the resolution or decision of the approving body on approving the statements and distributing the profit or covering the loss
- The management report, in the case of certain entities
If the statements were not approved on time, they are filed with the register within 15 days after that deadline and, once approved, filed again together with the documents (Article 69 section 2).
A joint-stock company approved its financial statements for 2025 at the ordinary general meeting of shareholders on 15 May 2026. Under the regulations, the final closing of the accounting books must take place by 30 May 2026, and the statements must be filed with the court register by 30 May 2026.
| Process stage | Deadline | Legal basis | Consequences of delay |
|---|---|---|---|
| Preparing the statements | By 31 March 2026 | Art. 52 sec. 1 of the Accounting Act | Fine or imprisonment of up to 2 years for failure to prepare (Art. 77 pt 2) |
| Approving the statements | By 30 June 2026 | Art. 53 sec. 1 of the Accounting Act | Unapproved statements filed with the KRS within 15 days (Art. 69 sec. 2) |
| Closing the books | 15 days after approval | Art. 12 sec. 4 of the Accounting Act | Breach of the regulations |
| Filing with the register | 15 days after approval | Art. 69 sec. 1 of the Accounting Act | Fine or restriction of liberty (Art. 79 pt 4), fines from the registry court |
Technical requirements for XML files
Preparing electronic financial statements in XML format requires meeting detailed technical requirements set by the Ministry of Finance. The XML file must comply with the current XSD schema, which defines the data structure and the permitted values of individual elements of the statements.
The basic technical requirements include:
- UTF-8 character encoding so that Polish diacritics display correctly
- Compliance with the XSD schema published on the e-Sprawozdania structures page
- Completeness of all required elements of the statements
- Correct date formatting in ISO 8601 format
- Correct indication of the reporting currency
The XML file of the financial statements must contain all required sections: the balance sheet, the profit and loss account and the notes. If any of these elements is missing, the validation system will reject the statements. Each section must be completed in line with the applicable accounting standards
XML files are validated at several levels. The first step is checking that the file structure complies with the XSD schema. The system then verifies the logical consistency of the data, including control totals and the correctness of links between individual items of the statements.
The most common technical errors in XML files are:
- Incorrect character encoding causing display errors
- Non-compliance with the XSD schema in terms of data structure
- Incorrect formatting of numbers and dates
- Missing mandatory elements
- Incorrect indication of the unit of measure
Before filing the financial statements, it is advisable to run a test validation of the XML file using the tools provided by the Ministry of Finance. This makes it possible to detect and remove technical errors before the statements are officially filed
Responsibility for the financial statements
Responsibility for correctly preparing, signing and filing the electronic financial statements for 2025 lies with specific people in the entity's organisational structure. The Accounting Act precisely defines the scope of this responsibility and the consequences of failing to meet reporting obligations properly.
The head of the entity bears the main responsibility for:
- Ensuring the financial statements are prepared on time
- Supervising the compliance of the statements with the Accounting Act
- Properly presenting the statements to the approving bodies
- Filing the statements with the court register on time
The head of the entity is responsible for performing accounting obligations even where they have been entrusted to another person or an accounting office; the acceptance of responsibility by another person or office must be confirmed in writing, and where the head of the entity is a multi-person body and no responsible person has been designated, all its members are responsible (Article 4 section 5). The head of the entity and members of the supervisory board are jointly and severally liable to the company for damage (Article 4a section 2)
Incorrect preparation or late filing of the financial statements may lead to various legal sanctions. The criminal provisions of the Accounting Act provide for a fine, restriction of liberty or imprisonment for breaches of accounting obligations (Articles 77 and 79). In addition, the registry court may call on the entity to file the statements and impose a fine in coercive proceedings (Article 24 of the KRS Act).
The chief accountant of a medium-sized manufacturing company was responsible for preparing the financial statements for 2025. Despite repeated reminders, she did not make sure the accounting software was updated to the new XML structures. As a result, the statements were rejected by the system and were filed again a month late, which exposed the company to a call from the registry court under threat of a fine.
Members of the bodies that approve the financial statements also bear some responsibility for the correctness of the process. The duty of due diligence requires them to check that the statements are consistent with the accounting records and to assess their completeness.
