The Polish tax administration is steadily introducing new obligations to digitalise tax settlements. One of the key elements of this process is JPK_KR, the Standard Audit File (Jednolity Plik Kontrolny, JPK) for accounting books. Taxpayers keeping accounting books must take into account changes that affect how accounting records are kept and how they communicate with the tax authorities.
The JPK_KR structure has applied since 1 July 2016 and is the standard format for providing accounting data to the tax authorities. It is submitted at the request of a tax authority (Article 193a of the Tax Ordinance Act (Ordynacja podatkowa)). Separately, CIT (corporate income tax) taxpayers keeping accounting books must file them once a year in a separate structure, JPK_KR_PD (JPK_CIT) – taxpayers filing the JPK_V7 for the first time for tax years starting in 2026, and the remaining taxpayers – in 2027.
JPK_KR is the Standard Audit File used to provide accounting books to the tax authorities. It contains data from the trial balance, the journal and the entries in the general ledger and subsidiary ledgers. From 1 July 2016 it applied to large entrepreneurs, while small and medium-sized entrepreneurs could voluntarily provide data in this form until 30 June 2018 (Article 29 of the Act of 10 September 2015, Dz.U. (Journal of Laws) 2015, item 1649); since 1 July 2018 it has covered all taxpayers keeping books using computer software
Current JPK_KR obligations on request
The JPK_KR structure (unlike the annual JPK_KR_PD) is submitted at the request of a tax authority. Taxpayers keeping accounting books using computer software must provide them in JPK_KR form during various audit and verification procedures.
The condition for complying with a request is keeping tax books using computer software (Article 193a § 1 of the Tax Ordinance Act). Taxpayers keeping accounting books have no choice, however: the CIT and PIT Acts require them to be kept using computer software (Article 9(1c) of the CIT Act, Article 24a(1e) of the PIT Act; the obligation is being phased in – for the last group of taxpayers for tax years starting in 2027, Article 66 of the Act of 29 October 2021).
The JPK structure for accounting books is not the only one that taxpayers using computer software must submit at the request of a tax authority. The JPK system covers a wide range of types of records, which allows the tax authorities to analyse business activity comprehensively.
Taxpayers must submit JPK files that comply with the XSD schema published by the Ministry of Finance. The current schema is available on gov.pl in the section on JPK structures. Failure to meet the technical requirements may mean the files have to be submitted again
Types of JPK files submitted on request
At present, the following JPK files are submitted at the request of a tax authority:
- JPK_KR - accounting books containing the full accounting records
- JPK_WB - bank statements from all bank accounts
- JPK_MAG - warehouse records and stock records
- JPK_FA - VAT invoices issued by the taxpayer (excluding structured invoices from KSeF (National e-Invoicing System) – Article 193a § 1a of the Tax Ordinance Act)
- JPK_FA_RR - VAT RR invoices for purchases from flat-rate farmers
- JPK_PKPIR - KPiR (tax revenue and expense ledger)
- JPK_EWP - revenue records of taxpayers on the flat-rate tax on recorded revenue (ryczałt)
Each of these files serves different audit purposes and may be requested depending on the nature of the case and the taxpayer's type of business. The tax authorities may request one or more types of file at the same time, depending on the needs of the proceedings.
The scope of the data reported is set by the tax authority taking into account the subject and stage of the case. It may therefore request one or more JPK structures from the list of files, depending on the period covered by the verification activities
How tax authorities request JPK_KR
Taxpayers are asked to provide specific JPK structures at the request of the tax authorities during various audit and verification procedures. Each of these procedures has its own specific purpose and may concern different aspects of business activity.
During tax proceedings, the authorities may request JPK_KR to verify that tax settlements are correct and that the amounts declared match the actual turnover. This is one of the most common situations in which taxpayers receive requests to submit JPK files. Requests often stem from discrepancies with returns, which is why it helps to know how to complete the VAT-7 (JPK_V7) return.
Verification activities are another area in which the tax authorities may request JPK_KR. These activities are of a verifying nature and are used to check that the accounting records are correct and comply with the applicable rules.
A tax audit is the most comprehensive form of checking a taxpayer's activity, during which the authorities may request the full range of records, including JPK_KR. An audit may cover different periods and aspects of the business.
A customs and tax audit covers in particular areas related to trade in goods, imports and exports, where JPK_KR can provide valuable information on financial and goods flows.
The tax authority may request specific JPK files from the taxpayer and, in connection with proceedings or an audit, also an extract from the books of a contractor if the contractor keeps its books using computer software (Article 274c § 1(2) of the Tax Ordinance Act). This means that an audit may also cover entities linked by transactions to the main subject of the audit
Deadlines and submission procedures
The deadline for submitting one or more JPK structures at the request of the tax authority is set in the request; in tax proceedings, the deadline for presenting evidence may not be shorter than 3 days (Article 189 § 2 of the Tax Ordinance Act). This is the minimum time the authorities must give taxpayers to prepare and submit the required files. Preparing the data can be harder in less typical cases, such as sales from several cash registers in JPK.
In justified cases, the taxpayer may ask for the deadline to be extended. Reasons may include the absence of the person responsible for the accounts or a large volume of data requiring extra time to prepare.
Failure to submit the JPK_KR file by the deadline set by the tax authority may result in a procedural fine (Article 262 § 1(2a) of the Tax Ordinance Act – up to PLN 3,800 in 2026 and up to PLN 3,900 from 1 January 2027) and, in certain situations, also in liability under the Fiscal Penal Code (Kodeks karny skarbowy, KKS). The scope of this liability – whether it is a fiscal petty offence or a fiscal offence – depends on the circumstances of the case.
Factors such as the amount of the tax shortfall, the offender's motives, the degree of social harm and the way the act was committed are particularly important. These elements determine the type and amount of penalties that may be imposed on the taxpayer.
Ways of submitting JPK files
JPK files on request may be submitted through various communication channels, which gives taxpayers flexibility in choosing the most convenient method. Each of the available methods has its own specific requirements and procedures.
- Application provided by the Ministry of Finance - the official government platform
- Commercial online applications - solutions offered by private providers
- Updated accounting software - direct sending from the accounting system
- Physical data carriers - USB stick, memory card, CD/DVD
Where files are submitted by electronic means of communication, the structured file should be signed with a trusted signature (Profil Zaufany) or a qualified electronic signature. This requirement ensures the authenticity and integrity of the data transmitted.
Where a file or files are provided on data carriers, a data download report is drawn up in electronic form. This report is the official confirmation that the records have been handed over and may be used as evidence in the event of a dispute
| Method of submission | Technical requirements | Electronic signature | Report |
|---|---|---|---|
| Government application | Web browser | Yes | No |
| Commercial applications | Internet access | Yes | No |
| Accounting software | System integration | Yes | No |
| Physical carrier | None | No | Yes |
Technical requirements and security
Submitting JPK_KR files requires appropriate technical and security standards. The files must be prepared in line with the current XSD schemas, which are regularly updated by the Ministry of Finance.
Particular attention should be paid to data integrity and protection during transmission. An electronic signature not only confirms the sender's identity but also makes it possible to detect whether the data has been modified during transmission.
Taxpayers using accounting offices should make sure that their accounting service providers are ready to handle all the required JPK formats and have the right tools to generate and submit them. Our overview of the obligations of accounting offices in 2026 lists the wider range of tasks they face this year.
A manufacturing company received a request to submit JPK_KR for the last three years in connection with a tax audit. The company had used different accounting systems during this period, which required files to be prepared in different formats. Thanks to backups and cooperation with its software providers, it managed to prepare all the required files within 7 days.
Mandatory filing of the books - JPK_KR_PD
The most significant changes to the JPK_KR system concern the introduction of mandatory filing of accounting books with tax offices. This means moving from a reactive system, in which files are provided on request, to a system in which the books reach the tax office without a request. Our accounting firm in Warsaw keeps accounting books and prepares JPK_KR files for its clients.
The changes were originally due to take effect from 1 January 2023, but were postponed because both taxpayers and the tax administration needed more time to prepare for the new obligations.
Mandatory filing of the books was introduced gradually (Article 66(2) of the Act of 29 October 2021, Dz.U. 2021, item 2105, as worded by Dz.U. 2023, item 1059). It first covered the largest taxpayers and tax capital groups, and later the remaining taxpayers.
The obligation follows from Article 9(1c) of the CIT Act: taxpayers keeping accounting books keep them using computer software and file them after the end of the tax year in the JPK_KR_PD structure (data from the fixed asset register – JPK_ST_KR – is exempt from filing for 2025–2028, Dz.U. 2024, item 1861 and Dz.U. 2026, item 1444). Accounting books are therefore sent by taxpayers to the tax office in structured form without a request
Timetable for introducing mandatory JPK_KR_PD
The timetable for mandatory filing of accounting books by CIT taxpayers is as follows:
For the tax year starting after 31 December 2024, the books are filed by tax capital groups and by taxpayers whose revenue for the previous tax year exceeded the equivalent of EUR 50 million. This group covers the largest corporations and entities with a significant impact on the economy.
For the tax year starting after 31 December 2025, the obligation applies to taxpayers required to submit the JPK_V7 (VAT return with records, SAF-T file). This is a significant extension of the obligation to most CIT taxpayers.
For the tax year starting after 31 December 2026, the remaining CIT taxpayers keeping accounting books will also be required to file them. This stage covers practically all entities keeping full accounting, except those exempt under Article 9(1d) of the CIT Act.
Accounting books in structured form are filed once a year, after the end of the tax year – not monthly or quarterly (Article 9(1c) of the CIT Act). PIT (personal income tax) taxpayers keeping accounting books file them under Article 24a(1e) of the PIT Act – for the first time for the tax year starting after 31 December 2025 (JPK_V7 filers) or after 31 December 2026 (others) – Article 66(1) of the 2021 Act
Filing deadlines in the new system
Under mandatory filing, taxpayers submit their books by set deadlines, regardless of any requests from the tax authorities. These deadlines are linked to the end of the tax year.
Since 1 July 2026, CIT taxpayers file their books by the end of the seventh month after the end of the tax year (Article 9(1c) of the CIT Act as worded by the Act of 15 May 2026, Dz.U. 2026, item 779); partnerships that are not legal persons under Article 9(1e) – by the end of the seventh month after the end of the financial year. For years starting in 2025 and ending before 1 April 2026, the same deadline was introduced by the regulation of 16 February 2026 (Dz.U. 2026, item 188).
Previously, the deadline was the day on which the deadline for filing the tax return for the given tax year expired. Since 1 July 2026, PIT taxpayers keeping accounting books file them by 31 July of the following year (Article 24a(1e)(2) of the PIT Act, Dz.U. 2026, item 779).
A limited liability company trading goods with an annual turnover of PLN 15 million, an active VAT payer filing the JPK_V7, whose tax year is the calendar year, files its books for the first time for 2026 – by 31 July 2027 – and for 2027 by 31 July 2028. The company must prepare its accounting systems to generate these files automatically.
Preparing for the JPK_KR changes
The obligation to file the books requires appropriate preparation by taxpayers. Above all, the accounting books must be fully computerised and meet the technical requirements.
Taxpayers should check whether their current accounting systems can generate JPK_KR files that comply with the current XSD schemas. Older systems may need to be updated or replaced.
Ensuring the continuity and integrity of accounting data is particularly important. Systems must be protected against data loss and unauthorised access, which is required not only for JPK_KR purposes but also under the general accounting rules.
It is also worth preparing internal procedures for generating and submitting JPK_KR files, including designating the persons responsible for these tasks and a schedule for carrying them out.
Taxpayers keeping accounting books using computer software must provide them in JPK_KR form at the request of a tax authority. This applies to all entities keeping their accounting records electronically, regardless of the size of the business
Impact on day-to-day accounting
Mandatory filing of the books affects day-to-day accounting in businesses. Accountants must ensure that all business transactions are recorded correctly and on time in computer systems.
Particular attention should be paid to the quality of the data entered into the accounting system. Errors and inaccuracies that could previously be corrected before an audit now reach the tax authorities together with the filed books.
It is also necessary to introduce additional control procedures to verify that the JPK_KR files generated are correct before they are submitted. This may include regularly checking control totals, verifying that the data is complete and that it meets the technical requirements.
Accounting offices serving many clients must organise their processes so that they can generate and submit JPK_KR files on time for all the entities they serve. This may require investment in additional systems and staff training.
Consequences of non-compliance
Failure to comply with JPK_KR obligations can have serious legal and financial consequences. The current rules provide for liability under the Fiscal Penal Code for failing to submit files by the required deadline.
The scope of liability under the Fiscal Penal Code depends on the specific circumstances of the case. It may be a fiscal petty offence or a fiscal offence, depending on the amount of the tax shortfall, the offender's motives and the degree of social harm.
Failing to file books that must be filed, or filing unreliable books, is punishable by a fine of up to 240 daily rates, and filing them late or with defects – by a penalty for a fiscal petty offence (Article 61a of the Fiscal Penal Code). The tax authorities are able to detect quickly cases of non-compliance with reporting obligations.
In addition, incorrect or incomplete JPK_KR files may become grounds for opening audit or verification proceedings, which can create additional costs and burdens for taxpayers.
Failure to submit the JPK_KR file by the deadline set by the tax authority may result in a procedural fine or liability under the Fiscal Penal Code. The scope of this liability depends on the circumstances of the case, in particular the amount of the tax shortfall and the offender's motives
Benefits of proper implementation
Despite the additional obligations, proper implementation of JPK_KR can bring taxpayers certain benefits. Above all, regular data submission can help tax matters to be handled faster and audits to take less time.
With access to accounting data, the tax authorities can carry out analyses without summoning the taxpayer, which may reduce the need for lengthy audits at the taxpayer's premises. This in turn may limit disruption to the day-to-day running of the business.
In addition, systematically providing correct data can build a positive image of the taxpayer as reliable and cooperative with the tax administration. This may have a positive effect on future relations with the tax authorities.
Implementing the modern accounting systems needed to handle JPK_KR can also help improve the efficiency of internal accounting and management processes in the business.
