Business Review Poland – June 2026

---

Key regulatory and business developments in Poland

June 2026 brought several important regulatory and business developments for companies operating in Poland. The main areas concerned AI in HR, JPK_CIT, JPK_KR_PD, KSeF, VAT deduction and extended deadlines for tax reporting.

For businesses, these changes mean that accounting systems, tax procedures, HR documentation and internal controls should be reviewed and adjusted to an increasingly digital and regulated environment. Data quality, compliance and clear responsibility for reporting processes are becoming more important.

---

AI in HR and employer obligations

The use of artificial intelligence in recruitment, employee assessment and performance monitoring requires careful compliance management. Under the EU AI Act, some employment-related AI systems may be treated as high-risk systems.

This may apply to tools used for filtering applications, evaluating candidates, allocating tasks, monitoring work or supporting decisions on promotion or termination. Employers in Poland should identify where AI tools are used, assess whether their outputs influence decisions concerning candidates or employees and ensure genuine human oversight.

An important practical obligation is AI literacy under Article 4 of the AI Act. Companies using AI systems should ensure that staff working with such tools have an appropriate level of knowledge. In practice, 2026 should be used to prepare HR procedures, documentation, provider verification processes and employee training.

---

JPK_KR_PD and foreign branches

The individual tax ruling of the Director of the National Revenue Information dated 2 April 2026, ref. no. 0111-KDIB1-2.4010.34.2026.2.EKB, is relevant for Polish companies with self-accounting foreign branches.

The tax authority confirmed a favourable position: the obligation to keep and submit accounting books under Article 9(1c) and 9(1e) of the Polish CIT Act should not cover accounting books kept independently by such foreign branches. This reduces the risk that full accounting books of foreign branches will have to be adapted to the Polish JPK_KR_PD structure.

However, the parent company remains responsible for correctly determining income, loss, tax base and CIT due in Poland. Companies should therefore document whether the branch is genuinely self-accounting and how branch data affects Polish tax settlements.

---

KSeF, PDF visualization and VAT deduction

In the National e-Invoicing System, KSeF, the core tax document is the structured XML invoice. A PDF visualization should only be a readable representation of the data submitted to the system.

The PDF must remain consistent with the structured invoice. Differences in amounts, descriptions, discounts, charges or settlement-relevant data may create VAT risks. In extreme cases, the tax authority may consider whether Article 108 of the Polish VAT Act applies, which may lead to the PDF being treated as a separate invoice showing VAT.

KSeF also affects the timing of input VAT deduction. For invoices issued directly in KSeF, the decisive moment is generally the date on which the KSeF number is assigned, provided the general conditions for VAT deduction are met.

If a supplier issues an invoice outside KSeF despite being required to use the system, the buyer should not automatically lose the right to deduct VAT, provided the transaction is genuine, the invoice meets formal requirements and the general deduction conditions are satisfied.

A transitional simplification applies to the smallest taxpayers in 2026: until the end of the year, invoices may be issued outside KSeF if the total gross value of sales documented by such invoices in a given month does not exceed PLN 10,000.

---

Extended JPK reporting deadline

The amendment signed by the President of the Republic of Poland on 11 June 2026 extends the deadline for submitting JPK files for income tax purposes by entities keeping accounting books.

The new deadline falls at the end of the seventh month after the end of the tax year or financial year. For taxpayers whose tax year corresponds to the calendar year, this will generally be 31 July.

The extension should help ensure consistency between accounting records, financial statements and income tax settlements, as annual financial statements in Poland are approved within six months from the balance sheet date. However, the scope of reporting has not changed. Companies still need to prepare accounting systems, charts of accounts, fixed asset records, JPK markers, contractor data, data mapping procedures and internal approval workflows.

Read the full article here: Business Review Poland – June 2026.

---

If you have any further questions or require additional information, please contact your business relationship person or use the enquiry form on the HLB Poland website.

Contact us »

***