The latest draft regulation of the Minister of Finance and Economy is sometimes interpreted more broadly than its wording actually allows. The draft dated 10 August 2026 does not suspend JPK obligations for CIT purposes, but introduces a temporary limitation applying only to fixed assets and intangible assets.
The exemption applies only to JPK_ST_KR
The draft provides for an exemption from the obligation to maintain the part of the records concerning fixed assets and intangible assets using computer software and from the obligation to submit those records in the dedicated JPK_ST_KR logical structure.
Other JPK obligations applicable for CIT purposes remain outside the scope of the exemption.
In particular, the obligation to submit accounting books in the JPK_KR_PD structure remains in force.
In practice, this means that the draft does not change the reporting requirements for accounting books, but only temporarily limits the obligations relating to fixed asset and intangible asset records.
The exemption is intended to cover 2026–2028
The proposed exemption is addressed to CIT taxpayers other than those specified in Article 9(1d) of the Polish CIT Act, as well as partnerships without legal personality.
It is intended to apply to a tax year, or in the case of partnerships without legal personality, a financial year, beginning after 31 December 2025 and before 1 January 2029.
In practice, this covers the years 2026–2028.
The reason is the limited readiness of IT systems
According to the explanatory memorandum, the solution is temporary and responds to the lack of sufficiently mature IT tools capable of fully and automatically maintaining the relevant records and generating JPK_ST_KR files.
The issue affects both smaller businesses and organisations using advanced ERP systems.
The draft therefore gives taxpayers additional time to adapt their accounting systems in the area of fixed assets and intangible assets.
Work on JPK_KR_PD should continue
From the perspective of CFOs and chief accountants, it is essential to distinguish between the two areas.
The 2026–2028 period may be treated as additional time to prepare systems for JPK_ST_KR, but not as a reason to suspend broader JPK for CIT implementation projects.
Work on JPK_KR_PD, including chart of accounts mapping, data preparation and data quality controls, should continue in line with the existing implementation schedule.
The regulation is still only a draft
At this stage, the regulation has not yet been published and is not yet in force.
The draft provides that it will enter into force on the day following its publication. Until the legislative process is completed, businesses should therefore continue to monitor both its progress and the final wording of the regulation.
The key conclusion is straightforward: the draft does not suspend JPK for CIT, but temporarily limits the obligations relating to JPK_ST_KR.
Please contact us if your organisation requires support in preparing for JPK obligations for CIT purposes or in assessing the readiness of its accounting systems.
We support businesses in preparing for JPK obligations for CIT purposes, including analysing the applicable scope, mapping the chart of accounts, assessing data quality and adapting accounting systems. We also help determine which implementation activities may be postponed in light of the proposed exemption and which should continue according to the existing schedule.
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