Tax customs & excise /

E-invoicing and JPK CIT: Are Poland’s taxpayers ready for change?

Poland’s taxpayers are facing significant changes in the area of e-invoicing and tax reporting. These changes will include the mandatory use of the National e-Invoicing System (KSeF) and the Single Control File for CIT (JPK CIT).

Although the topic of the KSeF and its recent postponement of its entry into force has been a high-profile one, work on the implementation of the CIT JPK continues uninterrupted. The postponement of the CIT JPK is not currently announced.

The mandatory application of the KSeF will commence on February 1, 2026 for businesses with annual sales of more than PLN 200 million, and on April 1, 2026 for others.

KSeF: Defer obligation until 2026

KSeF has been an optional solution since 2022, but only a small number of taxpayers have chosen to use it. In addition to adapting IT systems to the new form of invoicing, businesses may have to modify internal invoicing processes and procedures.

Due to the complexity of these changes, many taxpayers were relieved by the government’s April decision to postpone the mandatory KSeF. The deadline has been postponed until February 1, 2026 for entrepreneurs whose sales (including the amount of tax) will exceed PLN 200 million in 2025. PLN 200 million, and until April 1, 2026 for other entrepreneurs.

The decision to postpone and build the system architecture from scratch stems from the negative result of an external audit of KSeF, which confirms the complexity of the planned changes.

JPK CIT as early as January 1, 2025.

New tax reporting requirements

JPK CITs are logical structures that will enable businesses to report CIT electronically based on data from tax books. They will replace existing CIT returns and allow tax authorities to check tax settlements more quickly and efficiently, without the need to summon the taxpayer to show the books.

Who needs to prepare?

The first submission of the CIT JPK will be required for 2025 from CIT taxpayers whose income in the previous tax year exceeded EUR 50 million, and tax capital groups. After that, the obligation will extend to other taxpayers.

Key terms

Some taxpayers whose tax year overlaps with the calendar year should keep CIT JPK-compliant records starting January 1, 2025.

CIT JPK will be implemented on January 1, 2025, and will enable electronic CIT reporting based on data from tax books.

What is the current status of changes in e-invoicing and e-books?

The current design of CIT’s JPK logical structures and the timing for their implementation has raised a number of questions and doubts in the circles of tax law theorists and practitioners, including in the context of the KSeF deferral.

In order to minimize the disruption to a company’s day-to-day operations caused by sudden changes and to avoid penalties for failure to implement them, it is worth monitoring the ongoing legislative work on both KSeF and JPK CIT and taking advantage of the support of specialists in this area.

The enormity of the proposed changes seems to overwhelm even legislators. However, at a time of increasing global digitalization, they are inevitable.

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