Wojciech Chomicz

On December 17, 2025, a draft amendment to the PIT Act, CIT Act, and the Act on Flat-Rate Income Tax on Certain Income Earned by Natural Persons was published on the website of the Government Legislation Center (link). The aim of the draft is to extend the deadlines for reporting the Uniform Control File (JPK) in income taxes. However, the proposed changes will not affect all entities to the same extent.

Solutions proposed in the draft

1. Extension of the JPK reporting deadline for entities keeping accounting books until the end of the 7th month after the end of the tax year, i.e., until July 31 (if the tax year coincides with the calendar year). The deadline extension is intended for PIT and CIT taxpayers reporting the JPK_KR_PD logical structure.

The change will not apply to entities keeping other tax books, e.g., tax revenue and expense ledgers, which are required to submit JPK_PKPiR / JPK_EWP / JPK-ST. In their case, the deadline for submitting control files expires when the PIT return is filed, i.e., at the end of April.

1. The introduction of a simplification, thanks to which the power of attorney to sign declarations submitted by electronic means of communication will also entitle the taxpayer to submit JPK in income taxes.

The planned date for the adoption of the draft by the Council of Ministers has been set for the first quarter of 2026.

What about the largest taxpayers?

In the context of the planned changes, the question arises as to whether the deadline for reporting JPK CIT/PIT will remain unchanged for the largest taxpayers, i.e., entities whose revenues for the previous tax year (and in the case of companies that are not legal persons: the financial year) exceeded EUR 50 million, and for tax capital groups.

According to the current schedule, the first taxpayers will be required to submit their first JPK_KR_PD structures by March 31, 2026. At the same time, the Ministry of Finance has indicated that the draft amendment will not be adopted until the first quarter of 2026, which significantly limits the scope for any postponement of deadlines and their implementation in practice.

Consequently, we recommend that the largest taxpayers prepare for reporting by the originally scheduled date, i.e., March 31, 2026, treating any legislative changes as a risk factor rather than a baseline assumption for planning implementation activities.

Main objectives of the proposed changes

The proposed changes are a response to taxpayers’ requests that the deadline for reporting JPK CIT/PIT be after the approval of the annual financial statements. This solution avoids JPK corrections in situations where auditors make changes to the accounting books during the audit of the financial statements.

However, the planned postponement of the reporting deadlines for control files should not be synonymous with postponing implementation work. On the contrary, this time should be used to test tools and verify the correctness of data mapping and tags so that the final reporting process runs smoothly and without the risk of errors.

Exemption from the obligation to use book account tags for entities preparing financial statements in accordance with IAS/IFRS

Entities preparing financial statements in accordance with International Accounting Standards (IAS) and International Financial Reporting Standards (IFRS) are not required to use tags identifying accounting ledger accounts. This exemption results from § 5(2) of the Regulation of the Minister of Finance on additional data to be included in accounting books subject to disclosure under the Corporate Income Tax Act (Journal of Laws of 2024, item 1314).

Why do these entities not have to use tags?

Currently, there is no target tag dictionary for entities applying IFRS. This is directly related to the entry into force of IFRS 18, which significantly changes the presentation and classification of financial data. The new standard will be mandatory for reporting periods beginning on or after January 1, 2027.

Draft amendment to the regulation

At the beginning of December, a draft amendment to the regulation in question (link) was submitted to the Minister for signature, which provides for an extension of the exemption from the obligation to assign tags identifying accounting records until December 31, 2027. Although the draft amendment has not yet been signed, it is expected to be adopted soon. Failure to implement the amendment would result in the technical inability to introduce tags to accounting books, due to the lack of a developed tag dictionary for entities applying IAS/IFRS.

What remains unchanged?

The exemption applies only to the obligation to assign tags identifying accounting accounts. Other obligations under the JPK remain in force, in particular the obligation to submit the JPK_KR_PD file.