Table of Contents:
1. What is the timeline for the implementation of JPK_CIT?
2. What is the scope of JPK_CIT data?
Some taxpayers will be subject to mandatory JPK_CIT reporting starting from January 1, 2025. The Standard Audit File for Corporate Income Tax (commonly known as JPK_CIT) is a new reporting tool that will transform how financial data is submitted to tax authorities. It is essential for businesses to identify if they need to begin preparations before the first reporting period.
What is the timeline for the implementation of JPK_CIT?
In the first phase, the reporting obligation for the fiscal year starting after December 31, 2024, will apply to:
- CIT taxpayers whose revenue in the previous fiscal year exceeded EUR 50 million (converted to PLN based on the NBP average exchange rate on the last working day of the fiscal year); and
- Tax capital groups (PGK).
This means that these taxpayers will file JPK_CIT together with their CIT-8 return for 2025, which—if their fiscal year aligns with the calendar year—must be submitted by March 31, 2026. However, companies within tax capital groups and the largest firms with a fiscal year corresponding to the calendar year must maintain records starting January 1, 2025, to enable compliance with JPK_CIT requirements.
In subsequent years, the reporting obligation will expand to other groups of entities, specifically:
- For the fiscal year or financial year beginning after December 31, 2025: Other CIT taxpayers (non-corporate entities) required to submit JPK_VAT.
- For the fiscal year or financial year beginning after December 31, 2026: All remaining CIT taxpayers and non-corporate entities.
These groups will need to maintain books and records in line with new logical structures from January 1, 2026, and January 1, 2027, respectively.
What is the scope of JPK_CIT data?
Taxpayers will need to submit two files to the tax office:
- JPK_KR_PD – containing data on accounting books and corporate income tax settlements.
- JPK_ST – containing data on fixed asset records.
From a reporting perspective, the most critical regulation is the Finance Minister’s Ordinance of August 16, 2024, which specifies additional data required to supplement accounting books submitted under the Corporate Income Tax Act (Journal of Laws of August 29, 2024, item 1314). According to this ordinance, accounting books must be updated with additional identifiers for accounts used by entities.
The ordinance includes seven appendices with relevant account identification dictionaries applicable to:
- Banks,
- Insurance and reinsurance companies,
- Public benefit organizations preparing financial statements,
- Investment funds,
- Brokerage houses,
- Cooperative savings and credit unions,
- Other entities.
For the first reporting period (2025), transitional exemptions will apply to certain data to ease taxpayers into the new requirements. From January 1, 2026, companies will also need to provide details such as the contractor’s identification number, invoice identifier from the National e-Invoicing System, and the amount, type, and category of differences between accounting and tax results.
