Draft postponement of the JPK_CIT reporting deadline – why it matters for businesses in Poland in 2026

The draft postponement of the JPK_CIT reporting deadline is a response to practical challenges faced by finance, accounting and tax teams during year-end closing in Poland. The obligation to report accounting-book data in JPK structures for income taxes (including, among others, JPK_KR_PD and JPK_ST_KR, collectively referred to as JPK_CIT) requires not only generating technical files, but above all ensuring consistency between accounting and tax data.

In the current model, CIT reporting deadlines in Poland may fall before key annual processes are completed, such as:

• statutory audit of the financial statements (where applicable),
• approval of the financial statements,
• final closing of the accounting books after year-end adjustments.

This timing increases the risk that the data submitted in JPK files will later require corrections, or will not match the final state of the books after the full reporting cycle is completed.

---

What is expected to change – the new JPK_CIT reporting deadline

Extension of the deadline to the end of the seventh month after year-end

According to the draft, the deadline for submitting JPK files for income taxes for entities keeping full accounting books in Poland is to be extended to the end of the seventh month after the end of the tax year (or financial year).

For taxpayers whose tax year aligns with the calendar year, this would mean a potential shift:

• from the end of March (generally 31 March),
• to the end of July (generally 31 July).

---

Why the Ministry of Finance considers this change justified

The draft’s rationale links JPK_CIT reporting directly to accounting realities in Poland. As a rule, approval of the financial statements can take place up to six months after the balance-sheet date, and the final closing of the accounting books happens after the statements are approved. As a result, earlier reporting may force companies to submit data that does not yet reflect the final accounting entries.

---

Who the postponed deadline would apply to – and who it would not

The proposed extension is intended for taxpayers who:

• keep full accounting books (full accounting services in Poland),
• report data in JPK structures designed for income taxes.

At the same time, the draft indicates there is no justification for extending deadlines in the same way for PIT taxpayers using other tax records (e.g., the tax book of revenues and expenses), because in their case the obligation is not linked to approval of financial statements.

---

JPK income-tax reporting timeline – the broader context for JPK_CIT

The obligation to submit JPK structures for income taxes in Poland is being introduced in stages. In practice, this means some taxpayers report earlier (the “first wave”), while other groups are included in subsequent years.

First group – the largest taxpayers

The obligation initially covered, among others:

• tax capital groups,
• taxpayers with revenue exceeding the PLN equivalent of EUR 50 million.

For calendar-year entities, the date of the first reporting is particularly important. Under the proposed approach, the first reporting under the new timeline could fall on 31 July 2026.

Next stages

Further stages will include additional groups of taxpayers under transitional provisions. In practice, reporting will gradually cover a wider range of entities, which is why implementation planning should start early.

---

Why extending the deadline may improve reporting quality

1) Better consistency with the final accounting books

A later deadline allows companies to prepare JPK files after completion of activities that often lead to adjustments, such as:

• audit-related reviews,
• reconciliation of balances and classifications,
• adjustments to provisions and accruals/deferrals,
• changes in recognition and presentation of selected transactions.

This increases the likelihood that the submitted data matches the final, approved books.

2) Fewer corrections and follow-up explanations

Earlier reporting increases the chance that, after approval of the financial statements, a company will need to:

• regenerate the files,
• correct data within the required structures,
• perform additional reconciliations and document changes.

From an organisational perspective, an extended deadline can reduce iterations and the risk of inconsistency between financial documentation and JPK reporting.

3) More time for system work and testing

In practice, implementing JPK_CIT requires time-consuming work that is often underestimated, including:

• mapping data from the accounting system to JPK structures,
• validating tax markers and analytical dimensions,
• cleaning and standardising counterparty/master data,
• standardising transaction descriptions,
• testing tools that generate JPK schemas and performing file quality checks.

This is especially important when companies are managing multiple technology and regulatory projects at the same time.

---

Two different income-tax JPK deadlines – practical planning risks

The draft solutions may lead to a scenario where reporting deadlines differ depending on the type of records and the taxpayer’s status (e.g., full accounting in Poland vs. other tax records). In practice, this requires careful planning and clear determination of which files and datasets must be ready by specific dates.

The JPK_ST topic – risk of inconsistencies in fixed asset data

A key practical issue is the risk that JPK_ST (fixed assets and intangible assets register) may need to be submitted before final closing of the accounting books — i.e., before audit and approval adjustments are completed. Because fixed-asset data often changes during year-end work (e.g., depreciation, classification, valuation updates), submitting the file too early may result in:

• the need to submit later corrections to JPK_ST,
• inconsistencies between the fixed asset register and the final accounting books,
• additional organisational and control burdens for the taxpayer.

---

What businesses should do in 2026 – recommended actions

1) Continue preparations regardless of the legislative stage

Draft UD350 is currently in the government legislative process (included in the legislative work schedule). Until the new rules are adopted and enter into force, companies should assume the existing deadlines remain applicable. From an operational-risk perspective, pausing preparations is not recommended.

2) Treat JPK_CIT as a joint finance–tax–IT project

JPK_CIT combines accounting, tax and technology requirements. In practice, an effective approach includes:

• analysing the chart of accounts and its suitability for reporting,
• identifying accounts with mixed tax treatment and required analytical dimensions,
• standardising transaction descriptions and data standards,
• implementing data-quality controls before submission,
• technical tests and validations of files.

If you need support in aligning reporting work with year-end closing in Poland, consider professional accounting services in Poland and tax advisory in Poland delivered by getsix®.

3) Build an internal reconciliation calendar

For calendar-year companies, it is worth planning work in a clear sequence:

• year-end closing and accounting reconciliations,
• tax calculations and reconciliations with accounting figures,
• audit and adjustments (if applicable),
• approval of financial statements and finalisation of books,
• finalisation and verification of JPK_CIT,
• submission.

4) Review powers of attorney and file-signing rules

The draft assumes that JPK structures for income taxes will be covered by the UPL-1 authorisation. In practice, it is worth organising in advance:

• who signs and submits files,
• accountability for data verification,
• internal approval paths and documentation of controls.

For organisations entering or expanding in Poland, structured accounting in Poland can significantly reduce implementation risk and prevent last-minute reporting issues. Contact us.

---

Most common questions from businesses

Does the postponement mean a later CIT-8 filing?

No. The draft concerns the deadline for submitting JPK structures for income taxes. The annual CIT return (e.g., CIT-8) remains a separate obligation and, as a rule, is filed within the existing deadlines. In practice, this may separate the timing of the tax return and the JPK submission.

Will the postponement apply to all taxpayers?

The assumptions indicate the extension applies to taxpayers keeping full accounting books. For PIT taxpayers using other tax records, deadlines may remain different.

Does extra time mean you can delay preparations?

This is not recommended. In practice, the biggest challenges are data clean-up, mapping, standardisation and testing. If the extension is adopted, it should be used to improve data quality and consistency — not to postpone project start.

---

Legal basis:

• Draft act amending the Personal Income Tax Act, the Corporate Income Tax Act, and the lump-sum income tax on certain revenues earned by natural persons (draft no. UD350).

---

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 »

***