Poland JPK Explained: VAT, On-Request Files and JPK_PD

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6 years ago

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Status: In force, with different start dates by JPK layer. JPK_VAT with declaration has applied since 1 October 2020; JPK files on request apply to taxpayers keeping electronic tax books; annual income-tax JPK_PD is being phased in.

Verified on: 10 July 2026

Poland’s Jednolity Plik Kontrolny (JPK) is not one report. It is a family of structured tax files with different populations, frequencies and submission events. This editorial guide explains the obligation layers. It does not replace the separate Poland JPK implementation-service page, and it should not be read as a statement that one SAP deployment pattern covers every Polish entity.

Layer 1: JPK_VAT with declaration

All taxpayers registered as active VAT taxpayers submit JPK_VAT with both VAT-record and declaration data for periods from 1 October 2020. It replaces separate VAT-7 or VAT-7K filing for those periods. Two variants apply:

JPK_V7M: for monthly VAT settlement;
JPK_V7K: for quarterly VAT settlement.

Both are transmitted electronically every month, by the 25th day of the following month. If the 25th falls on a Saturday or statutory holiday, the deadline moves to the first working day. Quarterly taxpayers submit only the records section for months one and two of the quarter; for month three they submit that month’s records plus the declaration section for the whole quarter.

The file can be signed with a qualified electronic signature, Trusted Profile or authorising data where permitted. A successful submission produces an official acknowledgement, UPO, which should be retained with the final file and reconciliation evidence.

Layer 2: seven JPK structures on request

The tax authority can request structured records during checking activities, a tax proceeding, tax audit or customs-and-tax audit. The official list contains seven structures:

JPK_KR — accounting books;
JPK_WB — bank statement;
JPK_MAG — warehouse;
JPK_FA — VAT invoices;
JPK_FA_RR — VAT RR invoices for flat-rate farmers;
JPK_PKPIR — tax revenue and expense ledger;
JPK_EWP — revenue register.

Since 1 July 2018, taxpayers that keep tax books and create accounting evidence electronically can be required to provide these files. The request sets the exact deadline, which is at least three days. An extension may be requested where justified, but it is not automatic.

On-request JPK can be transmitted through the Ministry’s supported electronic tools or delivered on an accepted data carrier as instructed. The official guidance says not to send it by ordinary email or through ePUAP. This layer is evidence produced for a defined authority request; it is not the same recurring submission as JPK_VAT.

Layer 3: annual JPK_PD for income taxes

JPK_PD extends structured reporting to accounting books and records used for income taxes. Five structures are published: JPK_KR_PD and JPK_ST_KR for entities using accounting books, plus JPK_PKPIR, JPK_EWP and JPK_ST for relevant PIT records.

The official phase-in is based on tax years beginning after these dates:

31 December 2024: tax capital groups and CIT taxpayers whose prior-year revenue exceeded EUR 50 million. Their first JPK_KR_PD files are submitted in 2026. JPK_ST_KR is voluntary only for their 2025 period.
31 December 2025: other CIT and PIT taxpayers required to submit JPK_VAT monthly.
31 December 2026: remaining taxpayers, including quarterly JPK_VAT filers.

The general rule is submission after the tax year, by the deadline for the relevant annual tax return. A February 2026 regulation extended the first wave’s accounting-book submission in specified cases: for a qualifying tax or financial year starting after 31 December 2024 and ending before 1 April 2026, the deadline is the end of the seventh month after year-end. Apply that extension only to entities and periods within its wording.

The Ministry’s current guidance permits mandatory JPK_PD transmission through the API, with a 200 GB per-file limit, or Klient JPK WEB, with a 100 MB per-file limit. Use the current logical schemas and interface specification published in the JPK_PD downloads area.

What this means for an SAP landscape

The three layers require a shared data foundation but separate controls. JPK_VAT depends on correct VAT records, document attributes and monthly/quarterly logic. On-request files require the organisation to reconstruct the requested books, invoices, warehouse or bank data for the authority’s period at short notice. JPK_PD adds annual ledger and fixed-asset structures, phase-in classification and income-tax reconciliation.

Classify each Polish entity by VAT status, return frequency, taxpayer type, revenue threshold and tax year.
Map SAP tax codes, document types, business-partner identifiers and reporting markers to the current logical schemas.
Reconcile JPK_VAT to VAT accounts and the declaration before signing.
Keep extract capability for all seven on-request structures relevant to the entity; do not wait for an authority request to discover missing history.
Build JPK_KR_PD and JPK_ST_KR controls around the statutory ledger, fixed assets, year-end adjustments and the income-tax return.
Retain signed files, UPO acknowledgements, schema versions and correction history.

KSeF structured e-invoicing is a separate Polish regime. KSeF transaction processing may supply data used in tax reporting, but KSeF does not replace JPK_VAT, JPK_PD or an authority’s request for another JPK structure.

Primary sources

Regulatory information only; not tax or legal advice. Confirm entity classification, current schemas, deadlines and any transitional relief with the Polish Ministry of Finance and qualified Polish advisers.

For a system-by-system JPK scope and data-gap review, request a scoped SAP readiness review.

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