The Polish Ministry of Finance has published a draft regulation proposing a temporary deferral of the obligation to report fixed assets and intangible assets records within the JPK_ST_KR structure. Under the proposal, the exemption would apply to the 2026-2028 tax years, with reporting in the JPK_ST_KR structure becoming mandatory starting from the 2029 tax year. The proposal does not affect the JPK_KR_PD structure, and the existing reporting deadlines remain unchanged.
Why is this change important?
Preparing for reporting fixed assets and intangible assets data in the JPK_ST_KR structure is a complex and resource-intensive process. It requires the identification of relevant data sources, ensuring data completeness and consistency, proper mapping of data to the required structure fields, and adjustments to ERP systems as well as related accounting and tax processes.
In the explanatory memorandum to the draft, the Ministry of Finance points to the limited availability of IT solutions capable of supporting compliant maintenance and reporting of data within the JPK_ST_KR structure. The proposed deferral is intended to provide taxpayers and software providers with additional time to adapt their systems and processes to the new requirements.
The draft regulation is currently undergoing the legislative process and may still be amended before being formally adopted. Further details regarding the legislative process are available on the website of the Government Legislation Centre: : https://legislacja.rcl.gov.pl/projekt/12413608/katalog/13221582#13221582.
What does this mean in practice?
The proposal provides that during the 2026-2028 tax years taxpayers would not be required to:
- maintain fixed assets and intangible assets records in an electronic format compliant with JPK_CIT requirements;
- submit data from such records in the JPK_ST_KR structure.
The additional time should allow taxpayers to better prepare the data, systems and processes necessary for future JPK_ST_KR reporting.
Recommended actions
Despite the planned deferral of JPK_ST_KR reporting, organisations should consider planning their projects appropriately and spreading activities over time:
- Phase 1 – Assessment: evaluate data quality and availability, as well as ERP system readiness.
- Phase 2 – Gap analysis: identify deficiencies in data, systems and processes and determine the required remediation actions.
- Phase 3 – Solution design: develop a target model for collecting, processing and reporting data within the JPK_ST_KR structure.
- Phase 4 – Implementation: adapt systems and processes and incorporate JPK_CIT requirements into ongoing implementation and transformation projects.
- Phase 5 – Testing and reporting readiness: verify data completeness and accuracy and perform trial generation of the JPK_ST_KR structure.
How can PwC help?
PwC supports organisations in preparing for JPK_ST_KR reporting, from data and process assessments through to the implementation of a solution enabling the preparation, generation and validation of JPK files.
Our support may include:
- assessing the availability and quality of data required for JPK_ST_KR reporting;
- identifying gaps and mapping data from source systems to the structure fields;
- adapting data, processes and systems to reporting requirements;
- implementing a PwC solution supporting the preparation and generation of JPK_ST_KR files;
- performing testing, technical validation and consistency checks before reporting;
- training users and supporting the launch of the reporting process
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