Is JPK_CIT a file that the accounting system will generate once the year has been closed? No – the CIT Act (ustawa o CIT) requires books of account to be kept using computer programs and to be supplemented with additional data, above all with account tags. From the books for 2026, further data are added: the counterparty’s tax identification number (NIP), the invoice number in the National e-Invoicing System (Krajowy System e-Faktur, KSeF) and the differences between the accounting result and the tax result. These data arise at the time of posting, not at the time of export. In the JPK_V7, from the settlement for February 2026, every document has a KSeF number or an OFF, BFK or DI marking, and the later correction depends on that choice. We explain who submits books of account and for which year, by what deadline, and how to prepare the chart of accounts and the VAT records.
Who submits books of account in JPK_CIT and for which year
The first year for which a company submits its books of account in the structure of the Standard Audit File for Tax (Jednolity Plik Kontrolny, JPK) is determined by revenue, membership of a tax capital group (podatkowa grupa kapitałowa, PGK) and the way in which VAT records are submitted.
The obligation arises from Article 9(1c) of the CIT Act, and the logical structure from Article 193a § 2 of the Tax Ordinance (Ordynacja podatkowa). The sequence follows from Article 66(2) of the Act of 29 October 2021 amending, among other things, the CIT Act (table below). The second stage covers entities required to submit VAT records “in accordance with Article 109(3b)” (translation by the author) – a provision of the VAT Act (ustawa o VAT) that concerns taxpayers under Article 99(1), who file monthly returns. In a PGK, each company in the group submits books of account (Article 9(1g) of the CIT Act).
In an individual tax ruling of 21 January 2026, no. 0111-KDIB1-3.4010.737.2025.1.DW, the Director of the National Revenue Information Service (Dyrektor Krajowej Informacji Skarbowej) stated that “the wording of the provision of Article 66(2)(2) points to those taxpayers who submit the JPK_VAT records in the monthly variant (JPK_V7M)”.
The authority may argue that the stage is determined by registered VAT payer status alone. This argument is not decisive, because quarterly taxpayers submit their records under Article 109(3c), not under paragraph 3b – this is how the authority itself read the provision. The condition is an effective election of quarterly settlement (Article 99(2) and (3) of the VAT Act).
Determine the stage by reference to revenue, membership of a PGK and the way VAT is settled; confirm a change in the settlement method during the year with a ruling.
Stages of the JPK_CIT obligation (tax year coinciding with the calendar year)
| Stage | Who is covered | First books and deadline | Legal basis |
|---|---|---|---|
| I | PGKs; taxpayers and companies without legal personality with revenue in the previous year above the equivalent of EUR 50 million | for 2025, by the end of July 2026 | Article 66(2)(1) of the Act of 29 October 2021; § 1 of the Regulation of 16 February 2026 |
| II | entities submitting VAT records under Article 109(3b) of the VAT Act (JPK_V7M) | for 2026, by the end of July 2027 | Article 66(2)(2) of the Act of 29 October 2021; Article 9(1c) and (1e) of the CIT Act |
| III | all others, including those settling VAT quarterly (JPK_V7K) | for 2027, by the end of July 2028 | Article 66(2)(3) of the Act of 29 October 2021; Article 9(1c) and (1e) of the CIT Act |
| – | entities exempt from tax under Article 6(1), other than family foundations (fundacja rodzinna); taxpayers under Article 27a; entities keeping simplified revenue and expense records | no obligation | Article 9(1d) of the CIT Act |
Deadline: by the end of the seventh month after the end of the year
From 1 July 2026, books of account are submitted by the end of the seventh month after the end of the year – both by CIT taxpayers and by companies without legal personality whose partners are not exclusively natural persons.
The change was introduced by the Act of 15 May 2026 (Dz.U. z 2026 r. poz. 779). Until 30 June 2026, Article 9(1c) of the CIT Act referred to the deadline for filing the tax return (Article 27(1)) or the lump-sum tax return (Article 28r(1)), and paragraph 1e to the end of the third month after the financial year. From 1 July 2026, Article 9(1c) requires the books to be submitted “by the end of the seventh month after the end of the tax year” (ruling of 20 August 2026, no. 0111-KDIB1-1.4010.415.2026.3.BS).
A company covered by paragraph 1e submits the books itself, “by the end of the seventh month after the end of the financial year of those companies” (Article 9(1e)). In a ruling of 10 September 2026, no. 0111-KDIB1-1.4010.418.2026.1.BS, the authority stated that a general partnership (spółka jawna) that has filed the CIT-15J information, “although it is not a corporate income taxpayer, is obliged to submit the JPK_KR_PD file”.
For 2025 (calendar year), the deadline of the end of July 2026 followed from the regulation of the Minister of Finance and Economy (Minister Finansów i Gospodarki) of 16 February 2026, which covered only years ending before 1 April 2026. If a year that began in 2025 ends later, determine the deadline taking into account the transitional provisions of the Act of 15 May 2026.
The authority may argue that the seven months are available only to companies under Article 9(1e), since some rulings issued after 1 July 2026 – including the one of 10 September – cite paragraph 1c with the tax return deadline. This argument is not decisive: the new wording of paragraph 1c is cited in the rulings of 20 August 2026 and of 27 August 2026, no. 0114-KDIP2-2.4010.286.2026.1.AP, and the Ministry of Finance (Ministerstwo Finansów, MF) gives a deadline of seven months after the tax year or the financial year. In our view, this deadline applies to both groups.
In PIT, according to the MF, those submitting JPK_V7M keep their books and records exclusively in computer programs from 2026 and will submit them for the first time in 2027, while the others will do so for years beginning after 31 December 2026; the deadline is 31 July after the end of the tax year.
Account tags – the obligation concerns the books, not the file
Account tags are data with which the books are supplemented, so an account combining events with different tax consequences has to be split during the year, not when the file is generated.
The basis is Article 9(5)(1) of the CIT Act. The regulation of the Minister of Finance (Minister Finansów) of 16 August 2024 on additional data lists account tags according to dictionaries, which for most companies are those in Annex 7 (§ 2(1)(3)). They are assigned according to the classification criteria adopted for the entries in the books (§ 2(3)).
In a ruling of 12 August 2026, no. 0111-KDIB1-3.4010.260.2026.2.AN, the authority rejected assigning PD tax tags technically, when the JPK_KR_PD file is generated, without new accounts. It relied on Ministry of Finance answer no. 138: tags are applied “in the broadest possible manner”, and events of different content are posted to separate analytical accounts. The authority’s conclusion: taxpayers should “set up a separate analytical account (balance-sheet or off-balance-sheet) used to record NKUP”, i.e., costs that do not constitute tax-deductible costs.
The taxpayer may respond that the Accounting Act (ustawa o rachunkowości) does not require such a split. The MF acknowledges this – “This is therefore not an obligation arising directly from the Accounting Act, but a special tax regulation” – which is why the argument does not exempt the taxpayer from splitting the accounts.
A company taxed under the lump-sum corporate income tax (ryczałt od dochodów spółek) does not apply PD tags, although it does submit its books. In a ruling of 23 April 2026, no. 0111-KDIB2-1.4010.86.2026.1.AJ, the authority pointed out that under this regime “the CIT Act does not provide for an obligation to classify operations on an ongoing basis for the purposes of the tax result”.
Review the chart of accounts while still in 2026: set up separate analytical accounts for non-deductible costs (NKUP) and non-taxable revenue, and assign the tags.
Books for 2026: NIP, KSeF number and tax differences
The exemption in § 5(1) covered only the books for the year beginning in 2025, so for 2026 the books are supplemented with the NIP, the KSeF number and tax differences – also in companies that are only now entering the system.
Under § 5(1) of the Regulation of 16 August 2024, books “for the tax year that begins after 31 December 2024 and before 1 January 2026” are exempt from the data in § 2(1)(1), (2), (4) and (5). The provision specifies dates, not the first year of the obligation, so there is no such exemption for the second stage. In a ruling of 5 September 2025, no. 0111-KDIB2-1.4010.300.2025.2.BJ, the authority stated, with regard to a company not applying IFRS, that for 2025 “you will be obliged to supplement the books with the relevant so-called tax tags”.
Taxpayers preparing financial statements under IAS and IFRS may, however, omit the tags – following the amendment of § 5(2), in the books for years beginning “before 1 January 2028” (ruling of 27 August 2026).
The MF lists these data: the counterparty’s NIP, “if it has been assigned” (§ 2(1)(1)), the number identifying the invoice in KSeF, and the amount, kind and type of the differences between the accounting result and the tax result. The regulation divides the differences into eight categories (§ 2(1)(5)). Where a partner in a tax-transparent partnership submits books of account itself, it reports the partnership’s revenue (K_7) and costs (K_8) in the RPD node in proportion to its share in the profit (ruling of 10 September 2026).
The regulation of the Minister of Finance of 13 December 2024 granted an exemption from submitting the register of fixed assets and intangible assets (JPK_ST_KR) only for 2025. According to the MF, the additional data will not cover assets entered in the register before 1 January 2025.
Record the NIP and the KSeF number when posting the document, and record tax differences in the accounts feeding the RPD node. In a second-stage company, add these data for the months already posted.
NrKSeF, OFF, BFK and DI – what to enter in the JPK_V7 records
The entry is determined by the status on the day the records are filed: the KSeF number if the invoice has one, and otherwise OFF (failure only), BFK (invoice outside KSeF) or DI (document other than an invoice).
The JPK_VAT Regulation requires the KSeF number in the sales and purchase records (§ 10(2)(1)(g), § 11(4a)) and sets out the substitute markings in § 10(5) and § 11(8). OFF is “an invoice referred to in Article 106nf(1) of the Act”, i.e., one issued during a KSeF failure, without a number on the day the records are filed. BFK is “an electronic invoice and an invoice in paper form”, and DI is “a document other than an invoice”.
According to the Ministry of Finance brochure of January 2026, the KSeF number “is filled in when, on the date of filing the JPK_VAT, the invoice has been assigned a KSeF number”. For an invoice issued in offline24 mode (Article 106nda) or during a period of unavailability (Article 106nh(1)) that has no number on that day, the MF provides for the DI marking and its correction once the number is obtained; for OFF, according to the MF, a correction is not mandatory.
In a ruling of 12 June 2026, no. 0114-KDIP1-2.4012.181.2026.2.RST, the authority assigned BFK to invoices for intra-Community acquisitions of goods (wewnątrzwspólnotowe nabycie towarów, WNT) and imports of services. For the importation of goods on the basis of a customs document, it held that “the appropriate marking will in each case be the DI marker – as a document other than an invoice”. Notes documenting indirect discounts are recorded “both as documents marked WEW and as documents marked DI” (ruling of 13 July 2026, no. 0111-KDIB3-3.4012.181.2026.1.MAZ).
The authority may argue that an invoice issued in offline24 mode is not a document other than an invoice, and in the ruling of 13 July 2026 it linked DI to documents that “will not have a KSeF number”. The regulation does not resolve this case, so DI with a subsequent correction rests on the position of the MF. Protection comes only from a ruling of one’s own: the authority recalled there, citing the judgment of the Provincial Administrative Court (Wojewódzki Sąd Administracyjny, WSA) in Łódź of 27 March 2015, case ref. III SA/Łd 109/15, that rulings do not have the force of universally binding law.
Markings in the JPK_V7 records from the settlement for February 2026
| Document on the day the records are filed | Entry | After the KSeF number is assigned | Legal basis / source |
|---|---|---|---|
| Invoice with a KSeF number, including one issued in offline24 mode, during unavailability or during a failure | KSeF number | – | § 10(2)(1)(g) and § 11(4a) of the JPK_VAT Regulation |
| Invoice issued in emergency mode, without a number | OFF | correction not mandatory | § 10(5)(1)(a) and § 11(8)(1)(a); Ministry of Finance brochure |
| Invoice issued in offline24 mode or during a period of unavailability, without a number | DI | correction of the marking to the number | Ministry of Finance brochure |
| Invoice outside KSeF: consumer, WNT, import of services, period before the obligation, total failure | BFK | no correction, even after it is later sent to KSeF | § 10(5)(1)(b) and § 11(8)(1)(b); rulings of 12 June and 13 July 2026; Ministry of Finance brochure |
| Customs document on the importation of goods, accounting note documenting an indirect discount | DI (note – also WEW) | – | § 10(5)(2) and § 11(8)(2); rulings as above |
Configure a rule in the system: the KSeF number takes precedence, and the substitute marking follows from the channel and mode of issue recorded with the document.
Consistency with KSeF: one number in VAT, in the books and in the payment
The KSeF number links the VAT records, the books in JPK_KR_PD and – from 1 January 2027 – the payment, so record it once, when the document is booked, and reconcile it before each JPK_V7.
An invoice issued in offline24 mode is sent to KSeF no later than on the next working day after it is issued (Article 106nda(2)). An invoice issued during a period of unavailability is sent no later than on the next working day after the day on which the unavailability ends (Article 106nh(2)). An invoice issued in emergency mode is sent within 7 working days of the end of the failure indicated in the announcement (Article 106nf(4)).
If this deadline is met, an offline24 invoice has a number before the deadline for filing the JPK_V7 expires (the 25th day of the following month, Article 99(1) of the VAT Act). DI on such an invoice therefore means that the records were filed before the invoice was sent or that it was sent late, while OFF means a failure whose deadline for subsequent submission extends beyond the day the records are filed.
From 1 January 2027, the KSeF number or the collective identifier is also to be given in payments between registered VAT payers for a structured invoice (Article 108g of the VAT Act). An error in the number will therefore be replicated in the JPK_V7, in the JPK_KR_PD and in the transfer.
Keep a single register of documents with the channel, mode of issue, KSeF number and date of its assignment, and before filing the JPK_V7, reconcile the items marked DI and OFF with KSeF.
JPK_V7 corrections and resubmission of the books
Once the KSeF number has been assigned, according to the MF you correct the DI marking on an invoice issued in offline24 mode or during a period of unavailability; BFK and OFF entries do not need to be corrected.
For BFK, the authority held that the entry “will correctly reflect the factual situation as at the date of filing the JPK_VAT”, so a later sending of the invoice to KSeF by the supplier does not require a correction (ruling of 13 July 2026). It also accepted that an adjustment under bad debt relief (Article 89a of the VAT Act) repeats the marking of the original invoice – BFK or the KSeF number.
Article 9 of the CIT Act does not provide for a separate procedure for correcting books that have been submitted. If you change entries after submission – following the audit of the financial statements or when correcting the tax return – we recommend resubmitting the books in the JPK_KR_PD structure, with the RPD node reconciled with the corrected tax return.
The authority may treat a DI marking left in place as an error in the records, even where the tax has been reported correctly – the correction then concerns the marking, not the amounts.
Introduce a monthly review of DI and OFF items and a register of changes to the books made after the JPK_KR_PD has been submitted.
The most common mistake
The most common mistake is to treat JPK_CIT as an export run after the year has been closed, rather than as a change to the chart of accounts and to the description of events during the year.
An export will not assign a tag to an account in which events of different content have been recorded, and the authority does not accept a technical solution applied when the file is generated (ruling of 12 August 2026). Transferring entries from past months requires adjustment documents that record them according to the new classification criteria (Article 20(3)(4) of the Accounting Act).
Hypothetical example: a second-stage company that does not apply IFRS has, since January 2026, been posting to a single external services account both expenses treated as tax-deductible costs and expenses that it does not treat as such. The tag is assigned to the account, so in October the company has to set up a separate analytical account and re-post the entries for nine months.
How to avoid it: while still in 2026, compare the chart of accounts with the dictionary of tags, split mixed accounts, add fields for the NIP and the KSeF number, and assign accounts to the differences in the RPD node. The MF has provided for the generated JPK_KR_PD structure to be split into monthly, quarterly or half-yearly periods – so generate a test file for the closed months. In a third-stage company, introduce the changes from 1 January 2027.
Summary
- Determine the stage under Article 66(2) of the Act of 29 October 2021: PGKs and revenue above EUR 50 million – books for 2025, JPK_V7M – for 2026, all others – for 2027.
- Plan to submit by the end of the seventh month after the end of the year (Article 9(1c) and (1e) of the CIT Act) – books for 2026 by the end of July 2027.
- Rebuild the chart of accounts during the year: split mixed accounts, assign tags and, from 1 January 2026, record the NIP, the KSeF number and the differences for the RPD node.
- Mark documents in the JPK_V7 according to the status on the filing date: the KSeF number, OFF only for invoices issued during a failure, BFK for invoices outside KSeF, DI for other documents and – according to the MF – for offline24 invoices without a number.
- Correct the DI marking once the number has been assigned, and resubmit the JPK_KR_PD books if you change entries after submission.
Sources cited
All quotations from Polish-language sources — statutes, tax rulings and court judgments — are given here in the author's translation; the Polish wording is authoritative.
- Individual tax ruling of the Director of the National Revenue Information Service of 20 August 2026, no. 0111-KDIB1-1.4010.415.2026.3.BS – a taxpayer earning only exempt income (Article 27a of the CIT Act) does not submit JPK_KR_PD despite revenue above EUR 50 million; the wording of Article 9(1c) from 1 July 2026 and Article 66(2) of the Act of 29 October 2021. https://eureka.mf.gov.pl/informacje/podglad/705773
- Individual tax ruling of the Director of the National Revenue Information Service of 27 August 2026, no. 0114-KDIP2-2.4010.286.2026.1.AP – the books of a self-balancing foreign branch are not subject to submission in JPK_KR_PD or to supplementation with additional data; the wording of Article 9(1c) from 1 July 2026 and § 5 of the Regulation of 16 August 2024 after the amendment of paragraph 2. https://eureka.mf.gov.pl/informacje/podglad/707957
- Individual tax ruling of the Director of the National Revenue Information Service of 10 September 2026, no. 0111-KDIB1-1.4010.418.2026.1.BS – a general partnership that has filed CIT-15J submits JPK_KR_PD under Article 9(1e) of the CIT Act, whereas a foreign partner with no obligation to keep books in Poland does not; reporting of the partnership’s revenue by a partner in the RPD node. https://eureka.mf.gov.pl/informacje/podglad/708926
- Individual tax ruling of the Director of the National Revenue Information Service of 21 January 2026, no. 0111-KDIB1-3.4010.737.2025.1.DW – the second stage covers taxpayers submitting JPK_V7M; with quarterly VAT settlement, the obligation applies from 2027. https://eureka.mf.gov.pl/informacje/podglad/676209
- Individual tax ruling of the Director of the National Revenue Information Service of 12 August 2026, no. 0111-KDIB1-3.4010.260.2026.2.AN – PD tags must follow from the books; assigning them when generating the file without setting up separate analytical accounts does not fulfil the obligation. https://eureka.mf.gov.pl/informacje/podglad/704979
- Individual tax ruling of the Director of the National Revenue Information Service of 5 September 2025, no. 0111-KDIB2-1.4010.300.2025.2.BJ – scope of the simplification in § 5 of the Regulation of 16 August 2024; tax tags mandatory for 2025 for taxpayers not applying IFRS. https://eureka.mf.gov.pl/informacje/podglad/656738
- Individual tax ruling of the Director of the National Revenue Information Service of 23 April 2026, no. 0111-KDIB2-1.4010.86.2026.1.AJ – a company taxed under the lump-sum corporate income tax does not supplement its books with PD tags. https://eureka.mf.gov.pl/informacje/podglad/688174
- Individual tax ruling of the Director of the National Revenue Information Service of 12 June 2026, no. 0114-KDIP1-2.4012.181.2026.2.RST – BFK for invoices for WNT and imports of services, DI for a customs document on the importation of goods. https://eureka.mf.gov.pl/informacje/podglad/696196
- Individual tax ruling of the Director of the National Revenue Information Service of 13 July 2026, no. 0111-KDIB3-3.4012.181.2026.1.MAZ – BFK for an invoice received outside KSeF, with no correction after it is later sent to the system; notes as WEW and DI; markings for bad debt relief. https://eureka.mf.gov.pl/informacje/podglad/700467
- Judgment of the Provincial Administrative Court in Łódź of 27 March 2015, case ref. III SA/Łd 109/15 (final) – individual tax rulings do not have the force of universally binding law; cited by the Director of the National Revenue Information Service in the ruling of 13 July 2026, no. 0111-KDIB3-3.4012.181.2026.1.MAZ. https://eureka.mf.gov.pl/informacje/podglad/700467
- Ministry of Finance, “JPK_VAT with a return [JPK_V7M(3), JPK_V7K(3)]. Information brochure on the structure of JPK_VAT with a return” (JPK_VAT z deklaracją [JPK_V7M(3), JPK_V7K(3)]. Broszura informacyjna dot. struktury JPK_VAT z deklaracją), Warszawa, January 2026 – rules for entering the KSeF number and the OFF, BFK and DI markings, and for correcting the records after the number is assigned. https://www.podatki.gov.pl/media/wgbkrejs/broszura-jpk_vat-z-deklaracj%C4%85-od-1-lutego-2026-r.pdf
- Ministry of Finance, “JPK_PD”, the podatki.gov.pl website (updated 17 July 2026) – stages of the obligation and deadlines after the Act of 15 May 2026: seven months for CIT and 31 July for PIT. https://www.podatki.gov.pl/podatki-firmowe/jednolity-plik-kontrolny/jpk_pd/jpk_pd
- Ministry of Finance announcement of 26 August 2024 “New rules for digitising accounting records in CIT” (Nowe zasady cyfryzacji dokumentacji księgowej w podatku CIT) – additional data in the books from 1 January 2026, splitting of the structure and exclusion of assets from before 2025. https://www.gov.pl/web/finanse/nowe-zasady-cyfryzacji-dokumentacji-ksiegowej-w-podatku-cit
- Ministry of Finance announcement of 16 October 2025 “New rules on accounting records in PIT from 2026 – important information” (Nowe zasady dokumentacji księgowej w podatku PIT od 2026 r. – ważne informacje) – obligations of entrepreneurs settling PIT and submitting JPK_V7M. https://www.gov.pl/web/finanse/nowe-zasady-dokumentacji-ksiegowej-w-podatku-pit-od-2026-r-wazne-informacje
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Get in touch →Legal basis: Act of 15 February 1992 on corporate income tax (consolidated text: Dz.U. z 2026 r. poz. 554, as amended): Article 9(1c), (1d), (1e), (1g) and (5)(1), Article 27(1), Article 27a, Article 28r(1); Act of 15 May 2026 amending the Act on personal income tax, the Act on corporate income tax and the Act on lump-sum income tax on certain revenue earned by natural persons (Dz.U. z 2026 r. poz. 779): new wording of Article 9(1c) and (1e) of the CIT Act from 1 July 2026; Act of 29 October 2021 amending the Act on personal income tax, the Act on corporate income tax and certain other acts: Article 66(2); Act of 11 March 2004 on the tax on goods and services (consolidated text: Dz.U. z 2025 r. poz. 775, as amended): Article 89a, Article 99(1)–(3), Article 106nda(2), Article 106nf(1) and (4), Article 106nh(1) and (2), Article 108g, Article 109(3b) and (3c); Act of 29 August 1997 – Tax Ordinance (consolidated text: Dz.U. z 2026 r. poz. 622, as amended): Article 193a § 2; Act of 29 September 1994 on accounting (consolidated text: Dz.U. z 2026 r. poz. 522): Article 20(3)(4); Regulation of the Minister of Finance, Investment and Development of 15 October 2019 on the detailed scope of data contained in tax returns and in records relating to the tax on goods and services (Dz.U. z 2019 r. poz. 1988, as amended): § 10(2)(1)(g) and (5), § 11(4a) and (8); Regulation of the Minister of Finance of 16 August 2024 on the additional data to be added to the books of account submitted under the Act on corporate income tax: § 2(1)(1), (3) and (5), § 2(3), § 5(1) and (2) (paragraph 2 in the amended wording); Regulation of the Minister of Finance of 13 December 2024 on exemption from the obligation to submit part of the books of account under the Act on corporate income tax; Regulation of the Minister of Finance and Economy of 16 February 2026 on the extension of the deadlines for submitting books of account for corporate income tax purposes: § 1.