There are new obligations on the horizon related to the "Regulation of the Minister of Finance of November 20, 2023, on Additional Data to Supplement the Conducted Books Subject to Submission under the Corporate Income Tax Act", which will most likely enter into force from January 2025.
In accordance with the new regulation issued by the Polish financial authorities — "Regulation of the Minister of Finance of November 20, 2023, on Additional Data to Supplement the Conducted Books Subject to Submission under the Corporate Income Tax Act" — it is expected that the annual submission of JPK_KR accounting documentation will become mandatory.
The draft regulation has not yet been finalized. The latest version of the draft, "Regulation of the Minister of Finance of March 22, 2024, on Additional Data to Supplement the Conducted Books Subject to Submission under the Corporate Income Tax Act," and the XSD schema are still being analyzed by the Ministry of Finance's Process Consulting Office.
Is your company ready for these changes?
The new regulation and associated obligations are likely to come into effect from January 2025, with the first submission for large taxpayers and tax capital groups expected in January 2026 (for the 2025 report) — so the deadline is not far off!
This information is based on legislative and executive regulations that may be changed at any time by the relevant authorities, and therefore are not binding.
What Exactly Will Change – Key Information
The regulation aims to change the structure of the JPK_KR file to JPK_KR_PD and introduce a completely new structure for the JPK_ST_KR fixed assets file.
Key changes introduced in JPK_KR_PD compared to JPK_KR:
- Introduction of mandatory start and end dates of the tax year. The start and end dates of the reported period fields remain unchanged.
- Introduction of optional start and end dates of the financial year if they differ from the tax year. At this stage of development, we assume that the tax year always equals the calendar year.
- Introduction of eight different ZOiS1...8 nodes dedicated to various industries. Each node (except ZOiS8, which is dedicated to companies using IFRS) includes a list of financial statement position identifiers to be assigned to individual GL accounts, requiring companies to have separate GL accounts for all financial statement position identifiers.
- Companies using IFRS will need to create their own list of financial statement position identifiers as part of customizing the JPK reporting tool.
- Introduction of an additional marker (PD) for the GL account containing differences between the book value and the tax value, requiring companies to have separate GL accounts for all PD markers to be used in calculating CIT. In some cases, off-balance sheet accounts will need to be maintained.
- Introduction of a list of contractor numbers used in the Document Journal along with NIP and NIP country. The Document Journal has been expanded to include a new field containing the contractor number.
- Introduction of the invoice identification number in the National e-Invoice System (KSeF), if assigned.
Reference to Relevant Legislation and Additional Sources
- The draft regulation has been published (and updated twice) by the Minister of Finance in Poland. The full text can be found here: https://legislacja.rcl.gov.pl/projekt/12379367.
- 2351241 - SAF-T Poland: Release Strategy for "SAP Add-on for Polish SAF-T Regulatory Requirements (Private Cloud Edition/On-Premise)": https://me.sap.com/notes/2351241.
Plans for the Near Future
Intensive work is currently underway to update the Kreator JPK solution to handle the reporting capabilities of the JPK_KR_PD and JPK_ST_KR structures. The preliminary deadline for delivering the ready solution is planned for the fourth quarter of the current (2024) calendar year. More information on this topic can be found in SAP Note number 2351241.
The Ministry of Finance has provided the main guidelines regarding the formal and legal requirements for the mentioned JPK_KR_PD and JPK_ST_KR structures. However, the lack of detailed explanations from the Ministry in the form of published Ministry Brochures prevents providing an exact date when the ready solution supporting all the requirements related to the new JPK reporting obligation will be ready to start the implementation process.
Nevertheless, time is running out inexorably. To be ready for the final SAF-T or Kreator JPK solution implementation, we encourage you to analyze your SAP systems now to verify if the current system configuration and the processes supported by this system are adapted to meet the upcoming legal requirements. For those of you who cannot perform such an analysis independently, SI-Consulting has prepared an offer for such a service.
Interested parties are encouraged to contact us directly:
Jacek Wysocki: jacek.wysocki@si-consulting.pl, +48 600 615 500
Grzegorz Reszka: grzegorz.reszka@si-consulting.pl, +48 571 330 172
Krzysztof Banaszewski: krzysztof.banaszewski@si-consulting.pl, +48 660 43 00 92
In addition to the direct availability of our colleagues, we have also prepared a thematic webinar, to which we cordially invite you on two dates.
Summer with JPK
During the Summer with JPK webinars, our experts have presented the current state of work on Kreator JPK
