Document publication from the Polish ministry of finance:https://www.gov.pl/web/finanse/konsultacje-podatkowe-struktury-logicznej-jpkkrpd-oraz-nowej-struktury-jpkst

Who submits JPK KR PD?

The obligation to report tax books will cover CIT taxpayers whose revenue value in the previous tax year exceeded EUR 50 million and tax capital groups. The first JPK_KR_PD logical structures will be submitted in 2026 for the financial year starting after December 31, 2024. In the following years, the obligation will cover other groups of taxpayers, i.e. for the financial year starting after:

• December 31, 2025 – other CIT and PIT taxpayers are required to submit JPK_VAT,

• December 31, 2026 – other taxpayers.

Preparation and sending of JPK_PD

JPK files should be created using an accounting program and sent directly from the program if it has a JPK file-sending function.

The shipment can also be made using the JPK WEB Client application.

Reference: https://www.podatki.gov.pl/wyjasnienia/nowe-zasady-cyfryzacji-dokumentacji-ksiegowej-w-podatku-cit/

Obligation spread over time

In accordance with the regulations, the implementation of this obligation by individual groups of taxpayers has been spread over time. Entrepreneurs will have to submit the first logical structures of JPK_KR_PD in March 2026, i.e. by the deadline for submitting the tax return for 2025. Obliged entities will have to adjust their internal financial and accounting systems so that from 1 January 2025 they can generate accounting books according to the published logical structure. Additionally, a regulation has been developed specifying the scope of additional data that will have to be shown in the books kept.

In the first instance (i.e. for the tax year or financial year starting after 31 December 2024), it will cover:

• CIT taxpayers whose revenues in the previous tax year (and in the case of companies that are not legal persons - the financial year) exceeded EUR 50 million,

• tax capital groups.

These groups of taxpayers from the beginning of 2025 will have to include only one element in the logical structure of accounting books: markers identifying accounting books. Only from 1 January 2026 will they have to indicate the contractor identification number, the invoice identification number in the National e-Invoice System, the amount, type and type of the difference between the balance sheet result and the tax result.

In subsequent years, the obligation will cover further groups of entities, i.e. for the tax year or financial year starting after:

• December 31, 2025 – other CIT taxpayers (companies without legal personality) required to submit JPK_VAT,

• December 31, 2026 - other CIT taxpayers and companies other than legal persons.

The above groups of taxpayers will be obliged to keep books and records according to the new logical structures from 1 January 2026 and 1 January 2027, respectively.