JPK_KR_PD in 2027: Will Your Parent Company's Accounting System Meet Polish Requirements? - JWW Accounting office Poland, Wroclaw, Warsaw

JPK_KR_PD in 2027: Will Your Parent Company’s Accounting System Meet Polish Requirements?

Legal status as of 9 November 2026

Poland is extending its mandatory electronic reporting of accounting books in the form of the Standard Audit File for Tax (Jednolity Plik Kontrolny, JPK). For corporate income tax (CIT) purposes the relevant file is JPK_KR_PD. The largest companies have been reporting since 2025, and the remaining taxpayers join from 2027. For Polish subsidiaries and branches of foreign groups, the main challenge is often the accounting system run by the parent company or head office, which does not always produce a file that meets Polish requirements. Below we explain who is covered, what the deadlines are and how to prepare accounting in an international structure.

JPK_KR_PD: Who Already Reports and Who Joins in 2027?

The obligation to keep accounting books electronically and submit them as JPK_KR_PD follows from Article 9(1c) of the Polish CIT Act [1] and is being introduced in stages. Coverage depends on the tax year (or financial year) starting after a given date [2].

Stage	Tax year starting after	Who is covered	First submission (calendar year)
1	31 December 2024	Tax capital groups and CIT taxpayers (and certain partnerships that are not legal entities) with revenue above EUR 50 million in the previous tax year	by 31 July 2026 (data for 2025)
2	31 December 2025	Other CIT and PIT taxpayers keeping accounting books who file monthly JPK_V7M VAT returns	2 August 2027 (data for 2026)
3	31 December 2026	Other taxpayers, including those settling VAT quarterly (JPK_V7K)	31 July 2028 (data for 2027)

It is worth distinguishing two dates: when you must start keeping books under the new rules, and when you must first submit them. Companies covered from 2027 must have their books ready at the beginning of 2027, but will send the first file only in 2028.

The Act also provides for exclusions from the obligation, so the scope for a specific company should always be confirmed individually.

Deadlines: When to Submit JPK_KR_PD and What About JPK_ST_KR?

Since 1 July 2026, books must be submitted by the end of the seventh month after the end of the tax or financial year [3]. Earlier, for the first group of taxpayers, this deadline was temporarily extended by a regulation of the Minister of Finance and Economy of 16 February 2026 [4]. For a calendar year this means the end of July of the following year. Because 31 July 2027 falls on a Saturday, the deadline for 2026 ends on 2 August 2027.

A separate structure, JPK_ST_KR, covers the register of fixed assets and intangible assets. Under a regulation of 29 October 2026, which entered into force on 3 November 2026, the Minister of Finance and Economy exempted selected entities from keeping this register electronically and submitting it for years starting in 2026-2028 [5]. The exemption does not remove the obligation to submit accounting books in JPK_KR_PD or the obligation to keep records of assets. Companies should therefore check whether the exemption applies to them.

Foreign Accounting Systems and JPK_KR_PD: Where Do the Problems Appear?

In many corporate groups, accounting is run in one ERP system implemented by the foreign parent company. This simplifies consolidation and cost control, but it does not mean the system will deliver compliance with Polish JPK_KR_PD requirements. Simply using a system such as SAP, Oracle or Microsoft Dynamics settles nothing: what matters is the configuration, the completeness of data and the ability to generate Polish structures.

The most common difficulties are:

accounts not properly mapped to Polish tax markers,
missing data identifying counterparties,
difficulty showing the differences between accounting profit and taxable income,
incomplete integration of the fixed assets register,
inability to generate an XML file consistent with the logical structure published by the Ministry of Finance.

Do you need to replace the foreign ERP? Not always. Often the global system can be kept and a solution added that prepares the Polish JPK structures. The condition is access to complete and sufficiently detailed source data. An export to Excel or a standard accounting report does not guarantee a correct JPK_KR_PD file. The decision is best preceded by an analysis of accounting and tax processes and of the technical capabilities of the software.

Branch or Permanent Establishment? Which Foreign Companies Must Submit JPK_KR_PD

The scope of obligations depends on the form of business in Poland.

A branch of a foreign entrepreneur must keep separate accounting records in Poland under the Polish Accounting Act [6]. Coverage by JPK_KR_PD depends on the revenue of the Polish branch, not of the whole parent company. If that revenue exceeded EUR 50 million in the previous tax year, the branch belongs to the first group. The branch’s obligation does not depend on whether the parent reports similar data in its home country.

A permanent establishment without a branch or representative office does not keep full accounting books under the Accounting Act, and in tax rulings the authorities indicate that in such a case there is no obligation to submit JPK_KR_PD.

In practice, for a branch the key question is not whether the obligation exists, but whether data from the head office system can be translated into Polish structures. Accounting for the branch kept in Poland, under Polish rules, is the safest starting point. A separate issue is foreign branches of Polish companies: according to tax rulings, a self-balancing foreign branch generally does not have to submit its full books in JPK_KR_PD. For every structure, however, it is worth verifying the taxpayer’s status and how the activity is settled.

Penalties for Failing to Submit or Submitting Incorrect JPK_KR_PD

Failing to meet obligations related to accounting books and their submission may result in consequences under tax regulations and the Polish Fiscal Penal Code. Depending on the circumstances, relevant factors may include failure to submit data on time, submission of unreliable data or data inconsistent with the books, improper keeping of books and obstructing the authorities’ access to documentation.

The amount of the sanction and the classification of the breach depend on the specific act and the applicable provision. Not every delay or technical error means an automatic penalty. Liability may extend to the people responsible for financial and tax matters in the company, in line with the scope of their duties. Outsourcing accounting to a foreign head office or using a global ERP does not release a company from Polish obligations. That is why implementing JPK_KR_PD should be treated as part of tax risk management, not only as an IT task.

How to Prepare Your Company for JPK_KR_PD: A Checklist

Companies using foreign accounting systems should not wait until the first submission. Adapting the setup requires cooperation between the local finance team, the head office, the software provider and specialists in Polish accounting and tax.

Determine which group you belong to and from which tax year JPK_KR_PD applies to you.
Audit the accounting system: does it generate all data required in JPK_KR_PD and, where relevant, JPK_ST_KR.
Analyse the chart of accounts and map it to Polish markers, preferably at the start of the year rather than after year-end.
Verify tax data: transactions, counterparties, fixed assets and differences between accounting and tax results.
Choose how the file will be generated: directly from the ERP or through an export, transformation and validation process.
Test the files technically and substantively before the mandatory submission, including consistency with the CIT-8 return and JPK_V7 files.
Assign responsibility: who in the international structure prepares the data, checks it and submits it to the Polish tax authorities.

Is your company’s accounting ready for JPK_KR_PD?

JWW Biuro Rachunkowe has supported Polish and international companies for more than 25 years in accounting and in statutory reporting and tax obligations. We help subsidiaries and branches of foreign companies review their processes, identify gaps and plan the necessary changes. Thanks to partners within Alliott Global Alliance, we also provide services in more than 100 jurisdictions. We serve clients from Wrocław and Warsaw.

Phone: +48 501 077 071
E-mail: [email protected]

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Frequently Asked Questions (FAQ)

Is JPK_KR_PD mandatory from 2027?

The obligation is being introduced in stages. The largest companies have reported since 2025, the next group from the tax year starting after 31 December 2025, and the remaining taxpayers from the tax year starting after 31 December 2026. For the third group, the first file for 2027 is due in 2028.

What is the deadline for submitting JPK_KR_PD?

By the end of the seventh month after the end of the tax or financial year. For calendar year 2026 the deadline is 2 August 2027, and for 2027 it is 31 July 2028.

Does SAP, Oracle or Microsoft Dynamics meet JPK_KR_PD requirements?

This cannot be judged from the name of the software alone. The configuration, the availability of data and the ability to generate Polish structures must be checked.

Does the Polish branch of a foreign company have to submit JPK_KR_PD?

A branch keeps accounting books in Poland, so the obligation may apply to it. When it applies depends on the revenue of the Polish branch. A permanent establishment without a branch generally does not keep full books under the Polish Accounting Act.

Can JPK_KR_PD be prepared outside the main accounting system?

Yes, provided the data is complete, matches the books kept and meets the requirements of the relevant logical structure.

Is there a penalty for failing to submit JPK_KR_PD?

Legal Basis

[1] Article 9(1c) of the Act of 15 February 1992 on Corporate Income Tax (consolidated text: Journal of Laws of 2026, item 554, as amended).
[2] Act of 29 October 2021 amending the Personal Income Tax Act, the Corporate Income Tax Act and certain other acts (Journal of Laws, item 2105, as amended), transitional provisions on the JPK_KR_PD timetable.
[3] Act of 15 May 2026 amending tax acts as regards the deadline for submitting books, in force from 1 July 2026 (Journal of Laws reference to be confirmed: item 779).
[4] Regulation of the Minister of Finance and Economy of 16 February 2026 on extending the deadlines for submitting accounting books for corporate income tax purposes (Journal of Laws, item 188).
[5] Regulation of the Minister of Finance and Economy of 29 October 2026 on exemption from the obligation to keep electronically and submit part of the accounting books under the Corporate Income Tax Act (Journal of Laws, item 1444).
[6] Act of 29 September 1994 on Accounting, Article 2(1) (scope covering branches of foreign entrepreneurs; point number to be confirmed: point 7).