Since 1 October 2018, traditional paper-form financial statements have been replaced with electronic (digital) ones. All entities maintaining books of accounts are affected by this change. Audit reports must also now be submitted in digital format. Items to be included in this digital file is the original financial statement, as well as a copy of the printed version. Adoption of these requirements is in response to the European Parliament and Council’s directive 2017/1132, from June 2017. The digital form is intended for the following statements:
- Financial statements
- Statutory Management reports
- Consolidated financial statements
- Statutory management reports for the capital groups
- Reports of payments to public administration
- Consolidated reports of payments to public administration
- Audit reports
Digital format reporting should be signed with a qualified electronic signature. (This follows XAdES algorithm and encoding the personal identification number (PESEL) of the signing person is not required). According to the information from the Ministry of Finance, the qualified electronic signature issued in the European Union or a country outside the EU that meets the above requirements, is also accepted. Financial statements According to the Polish Accounting Act, updated 1 October 2018, financial statements, both single-entity and consolidated, are supposed to be prepared in electronic form and signed with the qualified electronic signature. Financial statements are signed electronically both by a person responsible for keeping the accounts, and company’s management, in compliance with the general regulations of the Accounting Act (e.g., all members of a management board for a private limited company). Furthermore, the financial statements of corporate entities listed in the Register of Entrepreneurs of the National Court Register (KRS), both single-entity and consolidated, and financial statements of personal income tax taxpayers who maintain the accounts and are obliged to submit financial statements, are supposed to be prepared in a special logical structure, and in a XSD (XML Schema Definition) file format, that has been made available in the Bulletin of Public Information (BIP) on the Ministry on Finances website. As for now, this is not required for the IFRS financial statements. Statutory management reports Statutory management reports of selected entities are also supposed to be made in electronic format and signed with a qualified electronic signature since 1st October. It concerns both the single-entity management reports as well as those of the capital groups. Unlike the financial statements, management reports require electronic forms only for corporate entities listed in Register of Entrepreneurs of the National Court Register. Therefore, this requirement does not relate to, for example, specialized open or closed investment funds. Audit reports Only the reports for the audits of corporate entities listed in the Register of Entrepreneurs of the National Court Register need to be in a digital format. It is worth mentioning, that the Polish Act on Statutory Auditors, Audit Firms and Public Oversight does not provide any requirements on how to sign other documents, e.g. limited review reports. Author: Wojciech Baucz, Partner at Avanta Audit Sp. z o.o. Sp.k., HLB Poland
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