Postponement of JPK_ST_KR – what is not included? CIT in SAP
The planned postponement of JPK_ST_KR gives companies more time to prepare the fixed assets and intangible assets report. However, it does not mean a delay of the entire JPK CIT.
This distinction is especially important for organizations already running projects related to JPK_KR_PD, preparing data in SAP, or organizing mappings and data sources.
The Ministry of Finance's project concerns the deferral of a specific scope: maintaining fixed assets and intangible assets records using computer programs and transmitting data from these records. It does not provide an analogous exemption for JPK_KR_PD.
In practice, the deferral should therefore lead rather to a change in priorities of the JPK CIT project than to its halt.
JPK_ST_KR and JPK_KR_PD – the deferral concerns only part of the JPK CIT obligations
The Ministry of Finance documentation clearly separates two structures:
- JPK_KR_PD – Uniform Control File for Accounting Books Income Tax,
- JPK_ST_KR – Uniform Control File for Fixed Assets.
The proposed exemption concerns the latter, i.e., the records of fixed assets and intangible assets.
The Ministry of Finance indicates in the Regulatory Impact Assessment that the exemption is to cover reporting periods 2026-2028. Its purpose is to give taxpayers additional time to adapt financial and accounting systems to the requirements related specifically to this area.
Therefore, this is not a deferral of all new obligations related to JPK in CIT.
Deferral of JPK_ST_KR does not cover JPK_KR_PD
For companies preparing for reporting, the most important consequence is simple: work on JPK_KR_PD still needs to be carried out according to the schedule appropriate for the organization.
The draft regulation does not include an exemption from reporting accounting books in the JPK_KR_PD structure. The scope of the proposed regulation is limited to fixed assets and intangible assets records.
It is therefore worth being cautious about brief messages about “JPK CIT deferral.” From a project implementation perspective, they may lead to the mistaken conclusion that all work can be postponed.
In organizations using SAP, it is more appropriate to split the project into two streams: JPK_KR_PD and JPK_ST_KR.
JPK_KR_PD in SAP remains a priority
The deferral of JPK_ST_KR does not change the need to prepare data required for JPK_KR_PD.
For companies working on SAP, tasks related to the chart of accounts, mapping, tags, identification of data sources, completeness of accounting entries, contractor data, and validation of information before file preparation remain relevant.
This is precisely where issues often arise that cannot be solved solely by technical configuration. If data sources are ambiguous or mapping requires many exceptions, the problem should be identified early enough.
The deferral of JPK_ST_KR may therefore be a good opportunity to shift more project team attention to JPK_KR_PD.
At Haergi, we help companies organize the project scope after legislative changes – separate work related to JPK_KR_PD and JPK_ST_KR and indicate which SAP elements and data require priority action.
Mapping JPK_KR_PD remains one of the key preparation stages
Data mapping is one of the areas not affected by the planned deferral of JPK_ST_KR.
In large organizations, simply assigning accounts to required categories is usually not the biggest challenge. More effort is needed to determine whether the adopted logic will be correct for different types of operations, companies, and system configurations.
Exceptions, local solutions, and the way data is supplemented outside SAP also matter.
Well-prepared mapping should therefore not be treated as a one-time table. It is an element of the entire reporting process that must remain consistent with source data.
JPK_KR_PD, SAP and SIT – data sources still require organization
One of the most important preparation stages for JPK_KR_PD is determining where the data actually comes from.
In simpler environments, most information may be directly in SAP. In more complex organizations, some data comes from other applications, internal solutions, and interfaces with external systems.
This matters for the quality of the entire process, so it is worth preparing a data source map in advance.
The earlier such a data map is prepared, the easier it is to plan further work and avoid situations where gaps are discovered only during file testing.
Deferral of JPK_ST_KR changes the schedule but does not justify stopping the JPK CIT project
From the SAP project perspective, the most important change is the possibility to spread work over time.
Some resources that were to work simultaneously on JPK_KR_PD and JPK_ST_KR can be redirected to KR_PD areas requiring earlier preparation. JPK_KR_PD remains the current work stream.
JPK_ST_KR can be planned over a longer horizon, especially regarding the final configuration of the reporting process or final solution testing.
However, this does not mean it is worth completely postponing the analysis of fixed assets data.
JPK_ST_KR in SAP – which tasks are worth continuing despite the deferral
The Ministry of Finance explicitly states that one reason for preparing the project is problems with the availability of IT solutions enabling full, automatic, and compliant maintenance of records and reporting of JPK_ST_KR.
Importantly, the Ministry of Finance notes that the problem also affects large enterprises using advanced SAP ERP systems.
Therefore, the additional time should not be treated solely as a deadline extension.
It can be used to analyze data in SAP FI-AA, check the completeness of master data, identify missing information, assess the quality of historical data, or determine which data will need to be obtained from other sources.
These are tasks that can be carried out earlier, even if the actual implementation of the JPK_ST_KR reporting process is postponed.
Haergi can support such a review even before starting the actual JPK_ST_KR configuration – from data source analysis to indicating areas worth organizing in SAP before the next project phase.
Deferral of JPK_ST_KR allows reprioritizing the project
The biggest benefit of the proposed change may be the possibility of more reasonable use of time and resources.
Instead of conducting all work simultaneously, companies can focus current efforts on JPK_KR_PD and prepare JPK_ST_KR in stages.
This approach reduces the risk that the deferral will be used solely to postpone problems.
JPK_ST_KR – the deferral is still at the project stage
Based on publicly available information, we are still talking about a draft regulation, not an already effective exemption.
The Ministry of Finance submitted the draft for public consultation on August 17, 2026.
The project documentation foresees consultations in Q3 2026, after which a consultation report will be presented.
The draft assumes that the regulation will enter into force the day after its announcement.
Until the legislative process is completed, it is better to speak of the planned deferral of JPK_ST_KR and simultaneously continue those parts of the JPK CIT project not covered by the proposed exemption.
JPK_KR_PD and JPK_ST_KR in SAP – organize the scope of work after changes
If the planned deferral of JPK_ST_KR affects your organization's project schedule, it is worth using this moment to reset priorities.
Haergi supports companies in preparing JPK_KR_PD and JPK_ST_KR, analyzing SAP data, mapping, identifying data sources, working with SIT, and validating information before reporting.
Contact Haergi if you want to check which elements of the JPK CIT project should be implemented now and which can be postponed without losing control over the entire implementation.
e-JPK in SAP