JPK CIT filing schedule from 2026
From 2026, entrepreneurs face new obligations related to sending JPK files. Changes in the implementation schedule concern both large companies and smaller taxpayers. Check who, when, and which files will have to be sent.
Schedule for implementing the JPK obligation for entrepreneurs
From January 1, 2025, CIT taxpayers and companies that are not legal persons, whose revenue in the previous tax year, and in the case of companies that are not legal persons, the financial year, exceeded 50 million euros and tax capital groups were required to submit data contained in both JPK_ST_KR and JPK_KR_PD files.
The deadline for submitting these files was set for the end of March 2026. However, for JPK_ST_KR files, this obligation was postponed by one year under the Ministry of Finance regulation dated December 13, 2024, as discussed later in this article. Meanwhile, the scope of required data for the JPK_KR_PD file for 2025 was significantly reduced.
From January 1, 2026, taxpayers CIT and companies that are not legal persons, as well as PIT taxpayers maintaining accounting books, who are obliged to submit JPK V7M files.
From January 1, 2027, the remaining CIT taxpayers and companies that are not legal persons. This means that by this date, the obligation to submit JPK CIT will include small CIT taxpayers who settle VAT quarterly and CIT taxpayers exempt from VAT. The same deadline applies to other PIT taxpayers maintaining accounting books, including those required to submit JPK_V7K files.
JPK_PKPIR, JPK_EWP, and JPK_ST structures will also be introduced gradually. From January 1, 2026, they will be mandatory for PIT taxpayers and those taxed with a lump sum on certain revenues earned by individuals, obliged to submit JPK_V7M files.
From January 1, 2027, for other PIT taxpayers and those taxed with a lump sum, including those required to submit JPK_V7K files, i.e., those settling VAT quarterly.
Deadlines for submitting uniform control files for 2026
CIT taxpayers who are active VAT payers and PIT taxpayers maintaining accounting books who settle VAT monthly must submit data for the financial year starting after December 31, 2025. JPK CIT files must be submitted by the deadline for filing the 2026 tax return. For entities whose financial year coincides with the calendar year, this is March 31, 2027.
JPK_PKPIR, JPK_EWP, and JPK_ST must be submitted for the first time in 2027 with data for 2026. The deadline for submission is April 30 of the year following the tax year to which the data relate. This means the first entities required to send these JPK files must do so by April 30, 2027.
These files must be sent electronically, in electronic form corresponding to the logical structure referred to in Article 193a § 2 of the Tax Ordinance.
Who do the new JPK CIT file regulations concern?
The regulations concerning JPK CIT primarily apply to all CIT taxpayers. They impose the obligation to submit JPK files to the competent head of the tax office. Submission is done via the Ministry of Finance servers, and files must be in XML format compliant with the XSD schema.
Such taxpayers submit two types of JPK files:
- JPK_KR_PD concerning accounting book entries,
- JPK_ST_KR concerning data from fixed assets and intangible assets records.
Although the name JPK CIT may suggest it concerns only taxpayers who are payers of corporate income tax, the reporting obligation applies to all CIT taxpayers and companies that are not legal persons and other PIT taxpayers. This includes those maintaining accounting books as well as those keeping the Revenue and Expense Ledger. It also applies to companies preparing tax settlements based on lump-sum taxation on recorded revenues.
This is because the new obligations related to JPK CIT files actually cover a wide range of JPK files. These files concern all entities participating in economic turnover. Here is the list of JPK files that must be submitted to the tax office:
- JPK_PKPIR – Uniform Control File for the Tax Revenue and Expense Ledger,
- JPK_KR_PD – Uniform Control File for Accounting Books Income Tax,
- JPK_ST – Uniform Control File for Fixed Assets for JPK_PKPIR and JPK_EWP,
- JPK_EWP – Uniform Control File for Revenue Records,
- JPK_ST_KR – Uniform Control File for Fixed Assets.
Postponement of the obligation to submit JPK_ST_KR structures
The obligation to report data contained in the fixed assets register and intangible assets has been postponed by one year. This is possible based on the regulations contained in the Regulation of the Minister of Finance dated December 13, 2024, on exemption from the obligation to submit parts of accounting books under the Corporate Income Tax Act.
Therefore, the first tax year for which the JPK_ST_KR structure must be submitted is the tax year starting on January 1, 2026, or later. This means that the deadline for submitting this file for entities whose tax year coincides with the calendar year is set for the end of March 2027.
It is worth noting, however, that this one-year postponement applied only to the largest entities that were originally required to submit the JPK_ST_KR file already for the year 2025.
Reduced requirements for the JPK KR PD structure for 2025
The Ministry of Finance issued a Regulation dated August 16, 2024, regarding additional data that must be supplemented in the accounting books subject to submission under the Corporate Income Tax Act.
According to Article 5, paragraph 1 of this regulation, "Books for the tax year beginning after December 31, 2024, and before January 1, 2026, and in the case of partnerships that are not legal persons, for the financial year beginning after December 31, 2024, and before January 1, 2026, may not be supplemented with the additional data referred to in Article 2, paragraph 1, points 1, 2, 4, and 5."
Under this provision, entities required to submit JPK KR PD for 2025 may include in the logical structure of their accounting books only one element: the tags identifying ledger accounts according to the dictionary contained in the Ministry of Finance regulation.
We encourage you to learn about our JPK offer in SAP – a solution that allows comprehensive handling of new JPK CIT (JPK_KR_PD) and JPK_ST_KR reporting obligations directly in the SAP environment. Thanks to this, your company can efficiently generate, verify, and archive files in accordance with the current guidelines of the Ministry of Finance quickly, securely, and without the need to invest in additional external systems.
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