New JPK structures and deadlines
– what is changing and how to prepare?
JPK extension - who will it cover and when?
New obligations regarding JPK CIT and PIT (Standard Audit File for income taxes) are implemented gradually, depending on the form of bookkeeping and the type of tax.
JPK_KR_PD structures
JPK_KR_PD is coming into force in stages to cover all entities keeping full accounting books, i.e. mainly companies and larger organisations.
The new structures apply:
- from 1 January 2025 - large CIT companies and tax capital groups (over EUR 50 million in revenues),
- from 1 January 2026 - other CIT and PIT taxpayers keeping accounting books,
- from 1 January 2027 - all other taxpayers, including those submitting JPK_V7K (quarterly settlements).
Learn how to implement JPK_KR_PD in accordance with the regulations - Implementation of JPK_KR_PD
JPK_PKPIR and JPK_EWP structures
These files will cover entrepreneurs keeping a tax book of revenues and expenses (PKPiR) or a revenue register (EWP).
These structures apply:
- from 1 January 2026 - PIT entrepreneurs submitting JPK_V7M,
- from 1 January 2027 - other PIT entrepreneurs and flat-rate taxpayers settling quarterly (JPK_V7K).
Entrepreneurs who sent JPK_V7M records to the tax office every month in 2025 will be obliged to keep all their financial records exclusively using computer programs from 2026.
Due to digitalization, these entities send tax books and records in a structured JPK format.
| Type of Records Kept | Required JPK Structures |
|---|---|
| Accounting Books | JPK_KR_PD (accounting books) |
| JPK_ST_KR (register of fixed assets and intangible assets) | |
| Tax Book of Income and Expenditures (PKPiR) |
JPK_PKPIR (tax revenue and expense ledger) |
| JPK_ST (register of fixed assets and intangible assets) | |
| Income Records (Lump Sum) | JPK_EWP (revenue records) |
| JPK_ST (list of fixed assets and intangible assets) |
Ministry of Finance project – extension of the deadline for JPK_CIT
On January 19, 2026, a draft regulation of the Minister of Finance and Economy regarding the extension of deadlines for submitting corporate income tax accounting records was published on the Government Legislation Center website.The document, developed by the Ministry of Finance and Economy, focuses on modifying the JPK-CIT reporting deadlines, which is a direct response to concerns raised regarding the submission of the Standard Audit File for Income Tax by entities maintaining accounting records.
The project assumes postponing the deadline for submitting JPK-CIT for 2025 for taxpayers keeping accounting books until the end of the 7th month after the end of the tax (or financial) year.
As announced, the Minister of Finance plans to adopt the above-mentioned project in the first quarter of 2026.
Amendments to JPK V7 in connection with the KSeF and the deposit system
The Regulation was published in the Journal of Laws regarding the detailed scope of data in tax returns and VAT records. The purpose of the changes is to adapt the current structure of JPK V7 to the National e-Invoicing System (KSeF).
Key changes:
- New invoice/document markings. Introduction of additional markings in JPK directly related to the implementation of KSeF.
- The obligation to mark the KSeF invoice in the purchase records. The obligation to include the KSeF invoice identification number in the purchase records.
- VAT on unrefunded deposits. Regulations regarding the settlement of VAT on deposits for packaging covered by the deposit system that have not been refunded.
JPK corrections
Doubts have arisen as to whether taxpayers will be required to correct JPK VAT files if an invoice issued offline did not yet have a KSeF number on the date the JPK was submitted. Tax advisors emphasize that such a requirement would be very burdensome.
The Ministry of Finance has confirmed that corrections to JPK_VAT files after the KSeF number has been assigned for e-invoices will not be necessary. It is important to ensure that a KSeF number has been assigned to the invoice on the day the JPK VAT file is submitted. If this number is not available, the taxpayer will not be required to correct the JPK file after it has been assigned.
JPK – what preparatory activities?
The new Standard Audit Files are not just "another file," but a complete representation of accounting. This forces entities to take a number of actions to help prepare for the changes.
- Data Audit. Ensure that tax identification numbers, document dates, amounts, and fixed asset inventory numbers are accurate and complete.
- System Updates. Verification that the financial and accounting software used (e.g., ERP systems) will receive updates that are compatible with the new JPK structures (e.g., JPK _KR_PD, JPK_PKPIR, JPK_ST).
- Test export and corrections. Generate test JPK files now. This way, you'll minimize chaos in 2026. Check how your system handles the correction process for KSeF numbers.
- Internal Training. New responsibilities require training for the accounting team. The sooner new procedures are implemented, the lower the risk of errors.
Don't be surprised - find out how we can help
The upcoming changes to JPK VAT pose challenges that require a strategic approach and immediate action. The scale of system and process modifications is enormous, and the margin for error is minimal.
Don't wait until the last minute, risking high correction costs and potential fines. Take advantage of a comprehensive analysis of your company's readiness for the new JPK and KSeF requirements! We'll help you design optimal processes and make strategic decisions to minimize costs and risk.
