SAF-T for CIT: Proposed postponement of JPK_ST_KR fixed asset reporting

The Ministry of Finance and Economy has published a draft regulation proposing a temporary exemption from the mandatory JPK_ST_KR (electronic fixed assets and intangibles register) reporting for the years 2026–2028.

The draft was issued on August 10, 2026. It is currently a legislative proposal and has not yet entered into force.

Key scope of the proposed exemption

Under § 1 of the draft regulation, eligible taxpayers will be temporarily exempt from two connected statutory duties:

• Maintaining electronic registers for fixed assets and intangible assets in the specific format required under Art. 9(1c) of the Polish CIT Act.
• Submitting this asset sub-ledger data electronically to the tax authorities via the JPK_ST_KR file format.

Important distinction: This exemption applies exclusively to the fixed asset sub-ledger and the JPK_ST_KR schema. It does not exempt taxpayers from keeping and submitting the rest of their electronic general ledger books. Companies subject to JPK_CIT reporting must still prepare and submit their JPK_KR_PD files as scheduled.

Eligible entities

The exemption covers taxpayers maintaining accounting books who would otherwise be obligated to generate and transmit JPK_ST_KR files under Art. 9(1c) of the CIT Act.

For partnerships and non-corporate entities subject to Art. 9(1e), the reporting obligation applies to entities whose partners are not exclusively natural persons. These entities will also fall under the proposed relief, provided they keep accounting records and meet the criteria of Art. 9(1c).

Application to Tax Capital Groups (PGKs)

The official Regulatory Impact Assessment (PL: Ocena Skutków Regulacji) explicitly confirms that the exemption will cover:

• Corporate Income Tax payers
• Partnerships / Non-corporate entities
• Tax Capital Groups (PGKs)

Ministry estimates indicate this regulation will impact 111 Tax Capital Groups and approximately 400,000 other corporate taxpayers maintaining full accounting records.

Covered fiscal years

The relief applies to tax or financial years starting after December 31, 2025, and before January 1, 2029. Eligibility is determined strictly by the start date of the fiscal year, not its end date.

• Calendar-year taxpayers: Exempted for 2026, 2027, and 2028.
• Non-calendar-year taxpayers: A fiscal year starting July 1, 2028, and ending June 30, 2029, will qualify for exemption. However, any fiscal year commencing on or after January 1, 2029, will not be covered.

Statutory filing deadlines for JPK_CIT

Under current CIT Act provisions (Art. 9(1c)), electronic accounting books must be submitted within seven months following the end of the tax year. For non-corporate entities under Art. 9(1e), the deadline is seven months following the close of their financial year.

Statutory asset sub-ledger requirements remain intact

This proposal is not a cancellation of standard fixed asset record-keeping. It solely waives the mandate to maintain these registers in a specific IT structure under Art. 9(1c) and transmit them via JPK_ST_KR.

Taxpayers remain fully obligated to track all data necessary to compute statutory tax depreciation under Articles 16a–16m of the CIT Act. Standard accounting and tax requirements continue to apply under:

• The Polish Accounting Act;
• General corporate tax rules governing asset depreciation and initial cost valuation;
• Accounting rules for asset upgrades, disposals, and write-offs;
• Internal financial control policies and accounting books.

Rationale behind the extension

Feedback received by the Ministry highlighted a widespread market issue: commercial accounting software and ERP systems currently lack mature, fully automated functionality to capture, format, and generate compliant JPK_ST_KR structures.

The Ministry recognized that system unreadiness affects companies of all sizes – from smaller firms using basic software to large multinationals running complex ERP architectures. This technical gap was acknowledged as an objective operational hurdle beyond taxpayers’ control, prompting the Ministry to grant additional runway for software vendors and corporate finance teams.

Practical implications & recommendations for finance leaders

While the draft regulation provides immediate operational relief and eliminates the pressure of rushing ERP fixed-asset module upgrades, finance teams should not pause ongoing data quality initiatives. The deferral is temporary, and full reporting will resume from 2029.

Finance Directors and Chief Accountants are advised to use this extended timeline to:

1. Audit Data Readiness: Verify whether current fixed asset registers contain all technical attributes required by the final JPK_ST_KR schema.
2. Reconcile Tax vs. Book Accounting: Align differences in historical cost basis, depreciation methods/rates, asset categories, and activation dates.
3. Map Data Sources: Identify all legacy tools, standalone applications, spreadsheets, and leasing software feeding the fixed asset register.
4. Clean Historical Records: Address missing documentation, past system migration errors, capital expenditure additions, and revaluations.
5. Establish Governance & Ownership: Clarify team accountability across accounting, IT, tax, and asset management for data validation and file sign-offs.
6. Track ERP Vendor Roadmaps: Coordinate with software providers to ensure JPK_ST_KR delivery schedules line up well ahead of the revised deadlines.

Effective date

The regulation is designed to take effect the day after its official publication in the Journal of Laws (Dziennik Ustaw). The short vacatio legis is intended to provide immediate legal clarity, as the exemption applies to obligations commencing in fiscal year 2026.

Executive summary

1. Temporary Relief for Fixed Asset Sub-Ledgers: The draft regulation provides a temporary exemption from the mandate to maintain electronically and submit fixed asset and intangible asset registers under the JPK_ST_KR schema.
2. Covered Fiscal Periods: The exemption applies to tax and financial years commencing after December 31, 2025, and before January 1, 2029.
3. Calendar-Year Entities: For taxpayers operating on a calendar-year basis, the relief covers 2026, 2027, and 2028.
4. Non-Calendar Fiscal Years: For non-calendar fiscal years, the exemption may extend into 2029, provided the fiscal year commenced in 2028.
5. Scope of Covered Entities: The proposal applies to Corporate Income Tax payers, partnerships/non-corporate entities, and PGKs.
6. No Waiver for JPK_KR_PD: The exemption does not apply to JPK_KR_PD or any other obligations concerning electronic book-keeping and general ledger submission.
7. Statutory Asset Tracking Remains Mandatory: The draft does not cancel general statutory requirements to maintain fixed asset sub-ledgers or accurately compute tax depreciation.
8. Time-Limited Relief: The exemption is strictly temporary and will not cover any tax or financial year commencing on or after January 1, 2029.
9. Current Legislative Status: The draft dated August 10, 2026, is not yet effective law. The exemption will become legally binding only after final enactment and publication in the Journal of Laws.

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Legal references

• Polish Corporate Income Tax Act of February 15, 1992 (Journal of Laws 2026, item 554, as amended)
• Draft Regulation of the Minister of Finance and Economy of August 10, 2026, on the exemption from maintaining electronically and transmitting fixed and intangible asset registers under Corporate Income Tax legislation