Poland (JPK)

An overview of Poland's Standard Audit File for Tax (SAF-T) implementation, known locally as JPK (Jednolity Plik Kontrolny).

Modules

Poland's SAF-T implementation (locally known as JPK - Jednolity Plik Kontrolny) consists of seven distinct modules, each representing a specific dataset that must be maintained and potentially reported:


Module	Description	Filing requirement	Deadline
JPK_VAT/V7	VAT records and declaration	Mandatory monthly or quarterly	25th day of the following month
JPK_FA	Detailed invoice data	On request	Within 3 days of request
JPK_KR	General ledger entries and accounting books	On request	Within 3 days of request
JPK_WB	Bank account operations and statements	On request	Within 3 days of request
JPK_MAG	Warehouse documents and inventory movements	On request	Within 3 days of request
JPK_PKPIR	Revenue and expense ledger (simplified accounting)	On request	Within 3 days of request
JPK_EWP	Revenue records for flat-rate taxpayers	On request	Within 3 days of request

Note:

While only JPK_VAT (now JPK _V7M/K) requires regular filing, tax authorities can request any of the other modules at any time, giving businesses just three days to produce compliant files. Your systems must be continuously prepared to generate all modules.

Possible penalties

Non-compliance with Poland's JPK requirements can result in severe penalties:

Failure to submit: Fines up to 3,000,000 PLN (around €670,000)
Late submission: Administrative penalties based on the delay period
Inaccurate data: Penalties proportional to the tax impact of errors
Fraud or intentional errors: Criminal liability for responsible individuals

If the value of tax liability reduction exceeds PLN 10,000, the offense may be classified as a tax crime rather than a misdemeanor, significantly increasing potential penalties.

Special considerations

Non-residents

Non-resident entities registered for VAT in Poland must comply with the same JPK requirements as local businesses with no simplified procedures or exemptions. Foreign companies must ensure their systems can produce Polish-compliant JPK files including all required elements and proper coding.

Small businesses

Businesses below VAT registration thresholds may be exempt from regular JPK_VAT filing, but if VAT-registered, all requirements apply regardless of size. There are no small business exemptions for on-request modules.

Industry-specific requirements

Certain industries face additional scrutiny through GTU codes (see file structure section), particularly:

Alcohol and tobacco (GTU_01, GTU_04)
Fuels and petroleum products (GTU_02, GTU_03)
Electronics dealers (GTU_06)
Vehicle sellers (GTU_07)
Precious metals traders (GTU_08)
Real estate transactions (GTU_10)
Professional service providers (GTU_12)

File structure

Poland's JPK_V7 structure is unique among SAF-T implementations globally, combining the VAT return and transaction records into a single file. The structure consists of three main sections:

Header section
- Taxpayer identification
- Reporting period
- Version information
- Type of submission (original/correction)
Declaration section
- Equivalent to the traditional VAT return
- Summary values for output and input VAT
- Special transaction totals and adjustments
Evidence section
- Detailed transaction records
- Split into sales and purchase registers
- Each transaction includes counterparty details, amounts, tax values, and specialized markings

Poland-specific GTU codes

Unique to Poland, transactions must be marked with specific GTU codes when they involve certain goods or services:


GTU code	Description	Examples
GTU_01	Alcoholic beverages	Spirits, wine, beer (>0.5% alcohol)
GTU_02	Motor fuels	Gasoline, diesel, biodiesel
GTU_03	Heating oil and lubricants	Specific oils as defined in excise legislation
GTU_04	Tobacco products	Cigarettes, cigars, tobacco
GTU_05	Waste management	Recyclable materials, waste processing
GTU_06	Electronic devices	Computers, smartphones, electronic components
GTU_07	Vehicles and parts	Cars, motorcycles, vehicle parts
GTU_08	Precious metals/stones	Gold, silver, diamonds, jewelry
GTU_09	Pharmaceuticals	Prescription drugs, certain medical devices
GTU_10	Buildings and land	Real estate transactions
GTU_11	Greenhouse gas allowances	Carbon credits, emission rights
GTU_12	Intangible services	Advisory, legal, accounting, management
GTU_13	Transportation/storage	Logistics, warehousing, transport services

Poland-specific procedure markers

Transactions must also be marked with specific procedure codes when applicable:


Marker	Description	Application
SW	Mail order sales	Distance sales to consumers in other EU countries
EE	Electronic services	Digital services, software, streaming
TP	Related party transactions	Transactions between affiliated entities
TT_WNT	Triangular transactions	Specific intra-community triangular transactions
TT_D	Triangular transactions	Triangular transactions (as second in chain)
MR_T	Margin scheme - tourism	Travel agency services under margin scheme
MR_U	Margin scheme - used goods	Second-hand goods under margin scheme
B_SPV	Split payment mechanism	Transactions using mandatory split payment
MPP	Split payment mechanism	Voluntary split payment transactions

Document type codes

Each document must be classified with the appropriate type code:


Code	Document type
FP	Invoices to receipts
RO	Internal documents
WEW	Internal documents
FVK	VAT invoice
KOR	Correction invoice
ZAL	Advance payment invoice
ROZ	Settlement document

Submission requirements

Deadlines

Businesses must file JPK_VAT returns either monthly or quarterly:

JPK_V7M (Monthly): Required for most businesses. Must be submitted by the 25th of the month following the reporting period.
JPK_V7K (Quarterly): Only available to small taxpayers who have notified the tax office of their election to file quarterly. These businesses must:
- Submit transaction records for first two months: By the 25th of the following month
- Submit transaction records for third month + quarterly declaration: By the 25th of the month following the quarter end

How filing frequency is determined

By default, all VAT-registered businesses file monthly (JPK_V7M). Small taxpayers (annual turnover below €2 million) may elect to file quarterly by submitting a formal notification to their tax office. Businesses in their first year of operation must file monthly regardless of size. Businesses that have committed certain tax offenses in the previous 12 months may lose their right to file quarterly. Missing these deadlines triggers immediate penalties, with no automatic grace period.

Filing formats & methods

File format: XML, conforming to the specific schema published by the Polish Ministry of Finance
Character encoding: Must use UTF-8 encoding
Submission methods:
1. e-Tax Office Portal (e-Urząd Skarbowy): Primary submission channel, suitable for most businesses
2. API interface: For automated submissions, requires certification
3. Client application: Desktop application provided by the Ministry of Finance
4. Emergency channel: Email submission only in specific approved circumstances

Note:

Unlike some countries, Poland does not accept alternative formats or submission methods. All files must be in the exact format specified by the tax authorities.

Authentication

Files must be authenticated using one of these methods:

Qualified electronic signature: Digital signature from an authorized provider, most common for businesses
Trusted profile (Profil Zaufany): Government authentication system for individuals and authorized representatives
Data authentication code: For authorized persons with specific permissions

Each authentication method requires prior registration and setup. Without proper authentication, files will be rejected regardless of content accuracy.

How to file

The process of filing Poland's SAF-T (JPK) requires careful preparation and submission through authorized channels. Follow these steps to ensure compliance with Polish tax authorities' requirements.

Prepare your JPK file.
1. Extract required data from your financial systems.
2. Apply proper GTU codes and procedure markers to transactions.
3. Validate file structure and content before submission.
Validate using government tools.
1. Use the official JPK validator application available from the Ministry of Finance website.
2. Check for structural, logical, and mathematical errors.
3. Resolve any validation issues before proceeding.
Access the e-Tax Office portal (Most common).
1. Log in using your qualified electronic signature or trusted profile.
2. Goto the JPK submission section.
3. Select the appropriate module and reporting period.
Upload and submit.
1. Upload your prepared XML file.
2. Verify the submission details.
3. Apply your electronic signature or other authentication.
4. Complete the submission process.
Alternative: API submission. For businesses with high transaction volumes, implement certified API integration:
- Configure automated submission with proper authentication
- Implement error handling and confirmation processing

If successful, you will receive an official UPO (Urzędowe Poświadczenie Odbioru) receipt that serves as your legal proof of submission.

Confirmation and follow-up

Upon successful submission, you will receive an official UPO (Urzędowe Poświadczenie Odbioru) receipt. This receipt serves as your legal proof of submission and should be preserved. Initial acceptance only confirms successful receipt, not data accuracy. There is no subsequent "approval" notification - you will only hear from authorities if there is an issue with your submission.

Post-submission process

The system performs automated validation checks
For JPK_VAT/V7, cross-checking with other taxpayers' submissions may occur
Validation issues can result in:
- Rejection notices requiring correction and resubmission
- Requests for clarification or additional information
- In some cases, audit initiation

Response requirements

Respond to any official inquiries within the specified timeframe (typically 7 days). Corrections must be submitted as complete new files, not just changed transactions. Each correction must be marked as a correction with reference to the original submission.

Archive expectations

All supporting documents and underlying data must be retained for 5 years from the end of the calendar year in which the tax deadline occurred. Electronic files must remain accessible throughout the retention period.

If original documents are electronic, they must be preserved in electronic form. System changes or upgrades must not compromise access to historical data.

Must be able to regenerate any submitted JPK file upon request. Supporting documentation must link clearly to reported transactions. Calculation methods and mapping decisions should be documented. Changes to data after submission must be tracked with explanation.

Archived data must be secured against unauthorized changes. Backup procedures must ensure data can be restored if primary systems fail. Access controls must be maintained throughout the retention period.

Poland's tax authorities may request access to source systems during audits, not just the submitted files. Your systems must maintain the ability to demonstrate how JPK files were generated from source data.

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