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Poland: Draft Regulation Would Suspend the JPK_ST_KR Fixed Asset Register Obligation for the 2026, 2027 and 2028 Tax Years

Country Update — Poland  |  20 August 2026  |  Topic: JPK CIT / Fixed Asset Register Reporting

On August 18, 2026 a draft Regulation of the Minister of Finance and Economy dated August 10, 2026, was made available in the Government Legislative Process service of the Government Legislation Centre (Rządowe Centrum Legislacji). The draft carries number 112 in the Minister's list of legislative works for the budget, public finance and financial institutions departments.

It would exempt corporate income tax payers, companies that are not legal persons and tax capital groups from two obligations at once — maintaining the register of fixed assets and intangible assets using computer software, and transmitting the data from that register in the dedicated JPK_ST_KR logical structure — for tax years beginning after December 31, 2025 and before January 1, 2029. The Ministry of Finance states its reason plainly in the regulatory impact assessment: the market does not yet offer financial and accounting systems that allow businesses to comply in full, and that is an objective obstacle independent of taxpayers' will and diligence.

Background

Poland's JPK reporting obligation in corporate income tax rests on Article 9(1c) of the Corporate Income Tax Act of February 15, 1992. Taxpayers keeping accounting books must maintain those books using computer software and transmit them to the competent head of the tax office after the end of the tax year, by the end of the seventh month following the end of that year.

The books must be transmitted by electronic means of communication, in an electronic form corresponding to the logical structure referred to in Article 193a § 2 of the Tax Ordinance Act, and in accordance with the transmission rules issued under Article 193a § 3 of that Act. The provisions entered into force on January 1, 2025. The seven-month deadline is the current wording, set by the amending Act of May 15, 2026 (Journal of Laws of 2026, item 779).

The obligation applies in three waves. For a tax year beginning after December 31, 2024 it covered tax capital groups and those corporate income tax payers, and companies that are not legal persons, whose revenue in the preceding tax or financial year exceeded EUR 50 million (JPK_KR logical structure).

For a tax year beginning after December 31, 2025 it extended to corporate income tax payers and companies that are not legal persons required to submit the JPK_V7M VAT records. From January 1, 2027 it reaches the remaining corporate income tax payers and companies that are not legal persons that did not perform the obligation for earlier reporting periods.

Two logical structures were developed for the new income tax JPK obligation: JPK_KR_PD, the Standard Audit File for accounting books and income tax, and JPK_ST_KR, the Standard Audit File for fixed assets. Both are due to the competent head of the tax office by the end of the seventh month following the end of the tax or financial year.

The JPK_ST_KR structure was separated (from the originally proposed JPK_KR structure) and covered the model of the logical structure regarding property, plant and equipment. The logical structure was made available in the Public Information Bulletin (Biuletyn Informacji Publicznej) on the website of the office serving the minister responsible for public finance, in accordance with the rules specified in the regulation issued by the minister responsible for public finance — the Regulation of the Minister of Finance of August 16, 2024 on the additional data with which accounting books transmitted under the Corporate Income Tax Act are to be supplemented (Journal of Laws of 2024, item 1314).

For fixed assets and intangible assets, that regulation is the source of the extended data set — data confirming the acquisition, production, or removal of a given fixed asset or intangible asset.

This is also not the first deferral of the fixed asset file. The Regulation of the Minister of Finance of December 13, 2024 on exemption from the obligation to transmit part of the accounting books under the Corporate Income Tax Act (Journal of Laws of 2024, item 1861) already exempted taxpayers other than those specified in Article 9(1d) of the Corporate Income Tax Act, and companies that are not legal persons, from transmitting the data from the register of fixed assets and intangible assets for a tax or financial year beginning after December 31, 2024, and before January 1, 2026. The practical effect was that the first period for which JPK_ST_KR would actually have to be produced became the tax year beginning in 2026 — the very year the present draft now proposes to relieve.

The Legislative Change

This item is a legislative instrument, not a technical artifact. It is a draft ministerial regulation, and until it is signed and published in the Journal of Laws it changes nothing. The obligation for the tax year beginning in 2026 stands meanwhile.

The legal basis is Article 9(5)(2) of the Corporate Income Tax Act, under which the minister responsible for public finance may, by regulation, specify groups of taxpayers other than those specified in Article 9(1d) of that Act, or companies that are not legal persons, exempted from the obligation to keep books using computer software or to transmit them in whole or in part under Article 9(1c).

Paragraph 1 of the draft exempts, first, taxpayers other than those specified in Article 9(1d) of the Corporate Income Tax Act for a tax year beginning after December 31, 2025 and before January 1, 2029, and second, companies that are not legal persons for a financial year beginning after December 31, 2025, and before January 1, 2029. The exemption runs from the obligation to maintain the register of fixed assets and intangible assets using computer software and to transmit that register by electronic means of communication under Article 9(1c). Paragraph 2 provides that the regulation enters into force on the day following its publication.

Two features distinguish the draft from the December 2024 instrument, and both matter. The first is duration: three consecutive tax years rather than one. The second is reach. The 2024 regulation was, on its own title and terms, an exemption from transmitting part of the accounting books. The present draft is an exemption from maintaining the register using computer software as well as from transmitting it. The justification is explicit that the exempted entities will also be relieved of the obligation to transmit data from that register using the dedicated JPK_ST_KR logical structure.

The regulatory impact assessment describes the beneficiaries as corporate income tax payers, companies that are not legal persons and tax capital groups, and characterizes the measure as a periodic exemption from part of the record-keeping obligations imposed by Article 9(1c). The stated purpose is to give taxpayers further time to align their financial and accounting systems with the new corporate income tax JPK requirements for these records.

Scope

The exemption is confined to the register of fixed assets and intangible assets. It does not touch JPK_KR_PD, and it does not touch the obligation under Article 9(1c) respecting the accounting books themselves. A taxpayer inside the first or second wave must still maintain its books using computer software and still transmit JPK_KR_PD by the end of the seventh month following its year end. This is a deferral of one file, not of the income tax JPK program.

The exemption is expressed by reference to the tax year for taxpayers and the financial year for companies that are not legal persons, in each case a year beginning after December 31, 2025 and before January 1, 2029. Groups with non-calendar year ends, therefore, need to map the window to their own year-start dates rather than to calendar years, and groups with entities on different year ends may find the window closing at different times across the group.

Taxpayers in the third wave, whose obligation begins for a year commencing after December 31, 2026, would fall inside the exempted window for their first two years of the obligation. In practical terms they would face JPK_KR_PD from the outset and JPK_ST_KR only later.

Nothing in the draft affects VAT reporting. JPK_V7M is referenced only as the criterion that identifies the second wave; the draft neither changes it nor changes the National e-Invoicing System obligations running in parallel.

Timeline

  • August 16, 2024 — Regulation of the Minister of Finance on the additional data with which accounting books transmitted under the Corporate Income Tax Act are to be supplemented (Journal of Laws of 2024, item 1314).
  • December 13, 2024 — Regulation of the Minister of Finance on exemption from the obligation to transmit part of the accounting books under the Corporate Income Tax Act (Journal of Laws of 2024, item 1861); the fixed asset register is exempted from transmission for a year beginning after December 31, 2024 and before January 1, 2026.
  • May 15, 2026 — amending Act sets the transmission deadline at the end of the seventh month following the end of the tax year (Journal of Laws of 2026, item 779).
  • August 10, 2026 — date of the draft Regulation of the Minister of Finance and Economy and of its regulatory impact assessment.
  • August 18, 2026 — the draft is made available in the Government Legislative Process service of the Government Legislation Centre; number 112 in the Minister's list of legislative works.
  • Third quarter of 2026 — public consultation and opinion-gathering, per the regulatory impact assessment, with a consultation report to follow.
  • Day following publication in the Journal of Laws — proposed entry into force of the regulation.

Businesses Affected

The regulatory impact assessment quantifies the affected population using Ministry of Finance data from the 2024 tax settlements, stated as at July 20, 2026: 111 tax capital groups, and approximately 400,000 other corporate income tax payers keeping accounting books. The impact is recorded as positive for both groups, being a periodic reduction of tax compliance burdens, and positive for micro, small and medium-sized enterprises as well as for large enterprises.

The population with the most at stake is not the smallest taxpayer but the multinational group running a large ERP estate. The JPK_ST_KR data set is drawn from asset accounting: parallel tax and accounting depreciation, dual depreciation rates expressed as both a percentage and an amount, the classification of fixed assets code and any change to it, the reason and date of retirement and the document evidencing it. In SAP terms that reaches into asset accounting configuration, depreciation areas, asset classes and the master data conventions applied over years of legacy postings.

The Ministry's own assessment names large entities operating advanced ERP systems alongside the smallest taxpayers as affected by the absence of adequate solutions.

Groups that treated the December 2024 deferral as a reason to stand down their asset data remediation are, on the Ministry's account of the problem, disproportionately represented among those now unable to comply. The same choice is available again, and carries the same consequence.

Shared service centers and outsourced finance functions are affected in a second way. Where the register is maintained on behalf of Polish entities from a regional center, the exemption — if adopted — removes a deliverable from the 2027 and later filing calendars, and the internal control documentation that references it will need to be updated rather than quietly left in place.

Required Actions

Do not stand down the asset data program. The relief is a draft, it is temporary by design, and it does not touch JPK_KR_PD. Treat it as additional time to finish a known piece of work, not as a cancellation.

Confirm which wave each Polish entity sits in and what its first JPK_ST_KR year actually was, then re-baseline the internal deadline while leaving the design and the data model in place. Where a project was scoped to deliver for the tax year beginning in 2026, the delivery date moves; the requirement does not.

Map the exemption window to actual year-start dates for every entity, including those with non-calendar year ends and those that changed year end. The window is defined by the date the tax or financial year begins, not by the calendar year to which the result is attributed.

Keep JPK_KR_PD firmly in scope, including the asset-related general ledger accounts within it. Depreciation and disposal postings continue to be reported through JPK_KR_PD whether the asset register itself is transmitted.

Take part in the consultation in the third quarter of 2026 if the outcome matters to you. The draft is to be sent to fourteen named business, accounting and tax-advisory organizations, including Konfederacja Lewiatan, Pracodawcy RP, the National Council of Tax Advisers, the Accountants Association in Poland and the Ombudsman for Small and Medium-sized Enterprises. The two questions worth putting are the interaction with the additional-data regulation of August 16, 2024 and the treatment of non-calendar tax years.

Monitor for publication in the Journal of Laws. Because entry into force is proposed for the day following publication and the regulation is intended to cover obligations for 2026 as well, there will be no lead time between adoption and effect — and equally no relief at all until that moment.

For SAP estates specifically: retain the asset accounting data model changes, the classification-of-fixed-assets mapping, the parallel tax and book depreciation area setup and the retirement reason coding. These are the long-lead items, they are the items the market reportedly cannot yet deliver, and they will be needed for the tax year beginning in 2029 regardless of what happens to the intervening years.

Practical Implications

The most striking feature of this draft is not the deferral but the reason given for it. A tax administration has stated in a formal regulatory impact assessment that the market currently lacks financial and accounting systems allowing businesses to comply fully with a reporting obligation it has itself imposed, that the problem is widespread, and that it affects the smallest taxpayers and operators of advanced ERP systems alike. That is an unusually candid assessment, and it is a useful document to have on file when explaining to a group's management why a Polish asset data project has proved harder than its scope suggested.

The risk this creates is complacency, and the pattern is already visible. The December 2024 regulation bought a year. A year later the Ministry reports that the underlying problem is unresolved. Deferring a report does not defer the data: the extended fixed asset attributes have to be captured as transactions occur, because reconstructing tax depreciation history, retirement reasons and classification changes retrospectively across several years of asset movements is materially harder and more expensive than capturing them prospectively. A three-year window used well removes the problem; a three-year window used as a reprieve reproduces it in 2029 on a larger asset population.

It is also worth being clear about the legal quality of the relief. Article 9(1c) is unchanged. What is proposed is an exemption granted by regulation under a statutory empowerment, for defined years, capable of being narrowed or replaced by a later regulation in the same way that the December 2024 instrument has now been superseded in substance. Planning assumptions built on the 2029 date should be held with that in mind, in both directions: the window may be extended again, and it may not be.

The entry-into-force mechanic deserves a note. A regulation taking effect the day after publication, and reaching obligations for a tax year already under way, is relief with retroactive effect. The justification addresses the point directly, asserting that this does not infringe the principles of a democratic state governed by law, which is the standard formula where a measure operates in the taxpayer's favor. The practical consequence for a compliance calendar is that the position can change without notice, so a taxpayer with a 2026 year end should not remove the JPK_ST_KR deliverable from its calendar until the regulation is actually published.

Finally, the draft is a reminder that Poland's digital reporting obligations are now dense enough that they interact. The same Polish entity is absorbing the National e-Invoicing System, the JPK_V7M records, JPK_KR_PD and, eventually, JPK_ST_KR, each with its own structure version history and its own deadline. Sequencing these as one program rather than four projects is what determines whether a deferral of one component is genuinely useful.

Expected Next Steps

The draft now goes through public consultation and opinion-gathering in the third quarter of 2026, with the results to be presented in a consultation report. No pre-consultation was carried out. The draft contains no technical regulations within the meaning of the national notification system and is not subject to notification, requires no submission to European Union institutions or the European Central Bank, and is stated to be consistent with European Union law — so the remaining path is domestic and, on the face of it, short.

After consultation the ordinary route is review by the Ministry's Legal Committee, signature by the Minister of Finance and Economy and publication in the Journal of Laws, with entry into force the following day. Given that the measure is intended to relieve obligations for a tax year already in progress, there is a clear incentive to complete that path well before the filing deadlines for years beginning in 2026 fall due.

Two things are worth watching during any deferral period. The first is whether the Ministry publishes a revised JPK_ST_KR logical structure while the obligation is suspended; a structure that changes during a three-year pause is a familiar pattern, and it is the reason a data model rather than a file mapping is the right thing to build now. The second is whether the Ministry issues guidance on the interaction with the additional-data regulation of August 16, 2024; the dedicated mailbox This email address is being protected from spambots. You need JavaScript enabled to view it. remains the channel the Ministry has published for questions on the JPK_KR_PD and JPK_ST_KR structures.

KGT will report on the outcome of the consultation and on the adoption and publication of the regulation, and will confirm the final wording of the exempted period, which is the operative detail for filing calendars.

How Can KGT Support You?

KGT is a specialist indirect tax technology firm. Our SAP-integrated e-invoicing and e-reporting add-ons generate, validate, and transmit country-compliant structured documents and statutory files directly from SAP ECC and SAP S/4HANA, keeping tax determination, document mapping, status handling, and the audit trail inside the system of record rather than in a downstream converter. Because the add-ons are validated against the current national schemas and code lists before transmission, a change of structure version becomes a configuration and regression-test exercise rather than a redesign. Where a client runs SAP Document and Reporting Compliance (SAP DRC), KGT delivers implementation, extension, and support services, including mapping to national customizations, eDocument and Statutory Reporting configuration, and the monitoring processes that turn a rejection into a resolved exception rather than an unfiled return.

For the questions raised by this update, KGT can assess your Polish asset accounting data against the JPK_ST_KR data set and the additional-data regulation of August 16, 2024, identify the gaps that require prospective data capture rather than retrospective reconstruction; confirm that JPK_KR_PD remains correctly scoped and reconciled while the asset file is suspended; re-baseline the delivery plan against the proposed exemption window mapped to each entity's actual year ends, and put a version-watch process in place so that a change to the structure during the deferral is picked up as a controlled change rather than discovered at the first filing.

Official sources

This Country Update is provided for general information only and does not constitute tax, legal or other professional advice.

Country update for Poland
19 August 2026
Poland
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