Poland: The Ministry of Finance Opens a Consultation on the JPK Tax-Tag Dictionary and Reissues the JPK Structures Register with JPK_MAG(2)
Country Update — Poland | 25 August 2026 | Topic: SAF-T / JPK Structures and Consultation
The Polish Ministry of Finance took two separate SAF-T actions in the week of August 17, 2026. On August 17, 2026 it reissued the official “Struktury JPK” register as version 48.0, which now carries the JPK_MAG(2) warehouse structure. On August 21, 2026 it opened a tax consultation on extending the PD tax-tag dictionary and adding new fields to the RPD node used in the JPK_KR_PD and personal-income-tax book structures, with comments due by September 15, 2026.
Background
Poland's SAF-T framework has two distinct workstreams that are frequently conflated. The VAT stream — JPK_V7M and JPK_V7K, now in their third schema generation and applicable from February 1, 2026 — is the one most multinationals track, because it is filed monthly and feeds directly off the VAT return.
The income-tax books stream is newer and structurally more demanding: JPK_KR_PD for corporate income tax under the Regulation of the Minister of Finance of August 16, 2024 (Dz.U. 2024 poz. 1314, as amended), and the personal-income-tax books and fixed-asset register under the Regulation of the Minister of Finance and Economy of September 6, 2025 (Dz.U. 2025 poz. 1311).
Within JPK_KR_PD, the tax-tag dictionary is the mechanism that carries the reconciliation between accounting profit and the income-tax base. Each ledger entry is tagged with a code that tells the administration how the accounting figure maps to the tax computation. The RPD node holds the reconciliation data itself. The dictionary is therefore not a cosmetic code list — it is the semantic bridge between statutory accounts and the tax return, and any extension to it changes what the chart of accounts has to be capable of expressing.
This is also the stream where the JPK_ST_KR fixed-asset register sits, which is the subject of the draft suspension regulation we covered on August 19, 2026. The two items in this article are separate from that draft and do not affect it.
The Change
Neither item is a change in law. The consultation is a pre-legislative step: the Ministry is inviting comment on a draft extension to code lists that live in the annexes to the two regulations named above, and any change would be made by amending those annexes. The structures register reissue is a publication event on the Ministry's official page.
Both are nonetheless operationally binding in prospect. Tax-tag dictionaries and XSD structures are the artifacts that determine whether a file is accepted, and Polish SAF-T structures are enforced by validation. Once an extended dictionary is adopted, the mapping work sits with the taxpayer, in the general ledger, and it cannot be deferred to a filing utility.
Scope
The consultation, opened August 21, 2026, covers a draft extension of the PD tax-tag dictionary and the addition of new fields to the RPD node. The Ministry's stated purpose is more precise mapping of the relationship between accounting profit and the income-tax base, and the notice states expressly that the exercise is also dedicated to entities reporting under IFRS — a significant clarification, because IFRS reporters have the widest gap between statutory accounting treatment and Polish tax treatment and have had the least guidance on how to express it in tags.
Four documents accompany the notice: the notification itself, the draft PD tag dictionary (Słownik znaczników PD), the draft dictionary of RPD node fields (Słownik pól węzła RPD), and a data-protection clause. Comments are to be submitted in editable format to
Separately, the “Struktury JPK” page maintained by the National Revenue Administration was reissued at 12:39 on August 17, 2026 as version 48.0; the previous version, 47.0, dated from January 23, 2026. The page now carries the JPK_MAG(2) warehouse structure, comprising Schemat_JPK_MAG(2)_v1-0.xsd, a matching PDF, an information brochure and a list of changes from version 1 to version 2 of JPK_MAG.
Two caveats apply to the second item. The page does not state what changed on August 17, so the association between the August 17 republication and the appearance of JPK_MAG(2) is an inference from the change history rather than a Ministry statement. And no official source states an application date for JPK_MAG(2); dates circulating in commentary are not confirmed by the Ministry and should not be planned against. Both points remain provisional until the Ministry publishes an accompanying announcement.
Timeline
- August 16, 2024 — Regulation of the Minister of Finance on CIT books, Dz.U. 2024 poz. 1314, establishing the tag annexes now proposed for extension.
- January 23, 2026 — previous version (47.0) of the “Struktury JPK” register.
- February 1, 2026 — JPK_V7M(3) and JPK_V7K(3) apply.
- September 6, 2025 — Regulation on PIT books and the fixed-asset register, Dz.U. 2025 poz. 1311.
- August 17, 2026, 12:39 — “Struktury JPK” register reissued as version 48.0, carrying JPK_MAG(2).
- August 21, 2026 — tax consultation on the PD tag dictionary and RPD node fields opens.
- September 15, 2026 — deadline for consultation comments.
Businesses Affected
The consultation affects every entity that files JPK_KR_PD, and IFRS reporters most of all. In practice that means Polish subsidiaries of multinational groups running a group chart of accounts under IFRS with a local statutory and tax overlay — precisely the population for which tag mapping is hardest, because the tagging has to be derived rather than read off the ledger.
The JPK_MAG(2) structure affects entities required to produce warehouse records on demand. JPK_MAG has always been an on-request structure rather than a periodic filing, which is why it attracts less attention than JPK_V7M — and why a schema change tends to be discovered during an audit rather than during a filing cycle.
Required Actions
- Read the draft PD tag dictionary and RPD field list against your own general ledger now, during the consultation window, rather than after adoption. The consultation is the last point at which a mapping that does not work for your accounting model can still be raised.
- IFRS reporters should treat the express reference to IFRS in the notice as an invitation and respond. Comments must be in editable format and reach
This email address is being protected from spambots. You need JavaScript enabled to view it. by September 15, 2026. - Assess whether your existing tag mapping in SAP — typically implemented through account determination or a dedicated tagging table — can absorb an extended dictionary without redesign. If tags are hard-coded rather than table-driven, that is the finding to surface now.
- Download Schemat_JPK_MAG(2)_v1-0.xsd and the official list of changes from version 1 to version 2, and confirm whether your extraction can produce the version 2 structure on request.
- Do not plan against any JPK_MAG(2) application date that is not stated by the Ministry. Monitor the “Struktury JPK” page and the National Revenue Administration announcements for a dated communication.
Practical Implications
The income-tax books stream is where Polish SAF-T becomes an accounting-architecture problem rather than a reporting problem. A VAT structure can be satisfied by a well-built extract; a tax-tag dictionary cannot, because the tag is a judgement about the tax character of a transaction and has to be assigned at or near the point of posting. Extending the dictionary raises the level of granularity the ledger must carry, and for IFRS reporters that often means either a parallel tax-account layer or a rules engine sitting between the ledger and the extract.
The consultation window is short — 25 days — and falls across the end of the summer. Groups whose Polish tax function is thinly staffed should assume they will not be able to respond meaningfully unless the work is triggered immediately, and should consider responding through a professional body if a direct submission is not feasible.
The structures register reissue is a smaller matter but illustrates a recurring problem with Polish SAF-T artifacts: the register is versioned, but the versions are not annotated. Version 48.0 replaced 47.0 with no published statement of what moved. The practical discipline is to snapshot the register periodically and diff it, rather than relying on notification.
Read together with the draft suspension of the JPK_ST_KR fixed-asset register obligation, the picture for 2027 is one of a Ministry still calibrating the income-tax books regime — deferring one component while deepening another. That is not a reason to slow preparation. The dictionary is being extended, not simplified.
Expected Next Steps
After September 15, 2026 the Ministry is expected to publish the outcome of the consultation and, if it proceeds, a draft amending regulation to the annexes of the 2024 and 2025 regulations. On JPK_MAG(2), the next expected event is a dated Ministry or National Revenue Administration communication stating an application date. The separate draft regulation suspending JPK_ST_KR for 2026 to 2028 continues on its own track.
How Can KGT Support You?
KGT is a specialist indirect tax technology firm working exclusively inside the SAP landscape. We deliver SAP-integrated e-invoicing add-ons for countries where a local mandate outpaces the standard SAP roadmap, and we implement and run SAP Document and Reporting Compliance (SAP DRC) where the standard solution is the right answer. Because we build and operate both, our advice on which route to take for a given country is not a sales position.
For the development described above, KGT typically helps clients in four ways: assessing the impact on the existing SAP configuration and interface build; carrying out the mapping and regression work against the current official specification version; managing the platform, provider or registration dependency; and running the resulting flows as a managed service, so that each release, schema version and validation change is absorbed for you rather than by you. To discuss what this means for your SAP landscape, contact KGT at
This publication is provided for general informational purposes only and does not constitute tax, legal, or professional advice. Please consult your advisor before acting on any information contained in this update.
