JPK_CIT in 2026: deadlines, JPK_KR_PD structure and new obligations (April 2026)

JPK_CIT has permanently changed the landscape of Polish accounting and tax reporting. The Standard Audit File for CIT taxpayers (commonly known as JPK_CIT) is no longer a distant plan of the Ministry of Finance – it has become a real requirement. This reform, based on the digitalisation of accounting books, has imposed on businesses an obligation to transmit data in a structured XML format.

Who must report, and when?

What does the new JPK_KR_PD structure look like?

Has the submission deadline been extended?

Below is a detailed analysis of the regulations in force in 2026.

What is JPK_CIT and why is it a revolution?

The introduction of the Standard Audit File for CIT is one of the final elements of tightening Poland’s tax system. Until now, tax authorities (KAS) could access accounting books mainly on demand – during inspections. From 2026 onwards (for the largest entities), this process becomes automatic and cyclical.

In practice, JPK_CIT is not a single file, but a new reporting standard that covers two main logical structures (schemas):

1. JPK_KR_PD – accounting books with corporate income tax data (an extension of the existing JPK_KR file).
2. JPK_ST_KR – a register of fixed assets and intangible assets (this obligation has been temporarily deferred).

The Ministry of Finance aims to be able to remotely verify the correctness of CIT settlements without the need to visit the company’s premises.

JPK_CIT implementation schedule: who does it apply to and from when?

The legislator has divided taxpayers into three groups, gradually extending the obligation to successive market sectors. It is essential to establish which group your company belongs to in order to prepare adequately for the new reporting obligations.

1. Group of “Large Taxpayers” and Tax Capital Groups (reporting for the 2025 tax year)

   These are the entities leading the way. The obligation to submit the JPK_KR_PD file for the 2025 tax year applies to:

   • Tax Capital Groups (PGK) – regardless of revenue.
   • The largest CIT taxpayers – companies whose revenue in the previous tax year (i.e. 2024) exceeded EUR 50 million.

   For these entities, Q2 2026 is the time to finalise the closing of books and generate XML files compliant with the latest schema published by the Ministry of Finance.

2. Group of VAT Taxpayers (obligation starting from 1 January 2026)

   This is the largest group, which has been in the reporting period for several months. It covers all CIT taxpayers who did not meet the EUR 50 million revenue threshold but are required to submit JPK_VAT records.

   • Important: This applies exclusively to taxpayers filing monthly VAT returns (JPK_V7M).
   • Obligation: From the first day of the tax year beginning after 31 December 2025 (i.e. typically from 1 January 2026), they must maintain books in a manner that enables JPK_CIT to be generated in the future.
   • First submission: Will take place in 2027 (for the 2026 tax year).

3. Group of Remaining Taxpayers (starting in 2027)

   This group includes entities filing quarterly JPK_VAT returns, entities not registered or registered as VAT-exempt, and specific organisations (e.g. family foundations). For them, the JPK_CIT reporting obligation will not apply until the tax year beginning after 31 December 2026.

JPK_CIT submission deadline: 31 March or 31 July 2026?

Under the CIT Act, the standard deadline for submitting accounting books in electronic form is the deadline for filing the annual CIT-8 return – i.e. the end of the third month after the close of the tax year (typically 31 March).

However, given the scale of technological challenges, the Ministry of Finance issued a regulation extending the deadline for the first year of reporting.

• New deadline: Under the regulation, for the largest taxpayers (Group I) the deadline for submitting JPK_KR_PD for 2025 has been moved to 31 July 2026.

In addition, advanced legislative work is underway to extend the JPK_CIT submission deadline for all CIT taxpayers subject to this obligation – the new deadline provides for submission of JPK_CIT by the end of the seventh month after the close of the tax or financial year.

The extended deadline will cover both JPK_KR_PD and JPK_ST_KR.

Logical structure of JPK_KR_PD – what does the file contain?

The new schema is much more than a digital balance sheet. It requires the “tagging” of accounting data so that the Ministry of Finance’s algorithms can understand the company’s tax specifics.

Key elements of the JPK_KR_PD structure:

1. Account tags (tax and accounting tags)*: The taxpayer must assign special tags from the Ministry of Finance’s dictionary to their chart of accounts. Tax tags distinguish, among others:
   • Non-taxable income – broken down into permanently and temporarily non-taxable revenue;
   • Costs permanently not constituting tax-deductible expenses (NKUP);
   • Costs not constituting tax-deductible expenses (NKUP) in the current year;
   • Tax-deductible costs and revenues in the current year, recognised in prior-year books;
   • Tax-exempt income;
   • Costs related to research and development activities.
2. Journal – a detailed record of all business transactions entered in the taxpayer’s accounting books.
3. Counterparty data in the journal: Every accounting entry relating to a transaction with a counterparty must include that party’s Counterparty Number, which is then linked to the Tax Identification Number (NIP) in the Counterparty register. This is a revolutionary change for companies that have previously posted cost invoices collectively or without full entity-level analytics in the general ledger.
4. RPD note – a summary reconciliation of the tax result to the accounting result, specifying the differentiating items (optional for 2025).

* The application of tags for entities preparing their financial statements under IFRS has been deferred to the tax year beginning on 1 January 2028.

Penalties and fiscal penal liability

Disregarding the new reporting obligations carries the risk of liability under the Fiscal Penal Code (KKS).

• Failure to submit the JPK_CIT file: May be treated as obstruction of a tax inspection or failure to fulfil a reporting obligation, subject to a fine.
• Submission of an unreliable file: If the data in the XML file (e.g. KUP/NKUP tags) is inconsistent with the actual state of affairs and results in an understatement of the tax liability, penalties may be significantly higher.
• Personal liability: Responsibility for the correctness of the books and JPK reporting lies with the head of the entity (Management Board) and persons entrusted with managing financial affairs (e.g. the CFO, Chief Accountant).

FAQ – JPK_CIT: questions and answers

If I am a quarterly VAT taxpayer, does JPK_CIT not apply to me in 2026?

That is correct. The legislator has included in the group starting in 2026 only those taxpayers who are required to submit monthly VAT records (filing JPK_V7M). If you file JPK_V7K, you must adapt your books from 1 January 2027.

Does JPK_CIT replace the CIT-8 return?

No. The CIT-8 return remains mandatory, regardless of the introduction of JPK_CIT. JPK_KR_PD is a supplementary document serving inspection and analytical purposes.

Do I need to use KSeF to submit JPK_CIT?

Formally, these are two independent obligations and systems; however, they are closely linked analytically. The KSeF invoice number should appear in the records, and the Head of KAS will use KSeF data to validate the accuracy of entries in JPK_CIT and JPK_VAT.

Can an accounting firm sign JPK_CIT?

Advanced legislative work is underway to introduce provisions that would allow tax books in income taxes to be signed on the basis of a power of attorney for signing declarations submitted by electronic means of communication (UPL-1). This solution will enable accounting firms to sign JPK_CIT.

Sources and legal basis (as of April 2026)

• Act of 29 October 2021 amending the Personal Income Tax Act, the Corporate Income Tax Act and certain other acts – the act introducing JPK_CIT and setting reporting deadlines for individual groups of taxpayers;
• Act of 15 February 1992 on corporate income tax – legal basis for submitting books in JPK_CIT format;
• Regulation of the Minister of Finance of 16 August 2024 on additional data with which accounting books subject to submission under the Corporate Income Tax Act must be supplemented – specification of additional data required in JPK_CIT;
• Regulation of the Minister of Finance of 13 December 2024 on the exemption from the obligation to submit parts of accounting books under the Corporate Income Tax Act – exemption from submitting the fixed assets and intangible assets register;
• Regulation of the Minister of Finance and Economy of 15 December 2025 amending the regulation on additional data with which accounting books subject to submission under the Corporate Income Tax Act must be supplemented – exemption from applying account tags for entities preparing financial statements under IFRS;
• Regulation of the Minister of Finance and Economy of 16 February 2026 on the extension of deadlines for submitting accounting books in respect of corporate income tax – extension of the JPK_CIT submission deadline;
• Act of 10 September 1999 – Fiscal Penal Code – penalties for failure to submit, errors or delays in JPK_CIT submission;
• Technical documentation of the Ministry of Finance – official XSD schemas and information brochures published on the podatki.gov.pl portal.

ALTO’s support in the area of JPK_CIT

Implementing JPK_CIT is a process that requires combining accounting and tax expertise with IT knowledge. If you wish to verify whether your company is ready to report in 2026, or if you need support in preparing for the new reporting obligation – contact our experts.

Our team will assist with analysing existing accounting and tax processes and adapting them to JPK_CIT requirements, ensuring full compliance with the Minister of Finance’s regulation.

We offer support with both the technical aspects of reporting, such as system configuration or the use of the ALTOOL JPK_CIT application enabling reporting, and substantive guidance on interpreting the new regulations. Drawing on our experience, ALTO can help companies identify areas requiring improvement, implement appropriate control procedures and ensure a smooth transition to the new legal requirements.

Contact us to obtain detailed information on JPK_CIT support and other tax and accounting services offered by ALTO.