Accounting Policy in the era of JPK_CIT. What the management board must know and is liable for

Who is required to have an Accounting Policy and on what legal basis

The obligation to maintain a written accounting policy arises from Article 10 of the Polish Accounting Act. This requirement applies to every entity that keeps accounting books. The accounting policy must be prepared in the Polish language and in written form.

In practice, this obligation covers, among others:

• capital companies, limited partnerships, and joint-stock limited partnerships (including those in organization),
• other legal entities,
• sole proprietorships as well as civil law partnerships, general partnerships and professional partnerships — once the revenue threshold is exceeded,
• entities operating in the financial sector — regardless of the level of revenue.

The head of the entity is responsible for establishing, signing and updating the accounting policy. Although the development of the policy may be delegated to an accountant or advisor, this does not transfer the legal liability.

Fines of up to PLN 15 million and 2 years in prison for unreliable accounting

The Accounting Act (Article 77) leaves no room for interpretation:

Failure to keep accounting books in accordance with the law, or entering unreliable data into the books, is punishable by a fine, restriction of liberty, or imprisonment for up to 2 years.

Even stricter provisions can be found in the Fiscal Penal Code (including Article 61):

For unreliable bookkeeping, penalties may reach up to 240 daily rates — which today may amount to as much as PLN 15 million.

And if the errors or omissions result in tax underpayment, the sanctions may be even more severe.

This is not a dead-letter law — authorities are increasingly enforcing these provisions. Especially now that JPK_CIT grants them full insight into accounting data. Any inconsistency, gap or outdated accounting policy may serve as grounds for proceedings and personal liability of management board members.

Imposed penalties also carry serious business consequences, including, among others: loss of credibility with banks and auditors, additional tax assessments, disputes and extra costs.

Accounting Policy before and after the introduction of JPK_CIT

The key elements of the accounting policy to date include:

• The financial year and reporting periods, ensuring comparability of data
• Defined methods of valuation of assets and liabilities to ensure consistency in results, provisions, inventories and accruals
• The chart of accounts, providing a clear classification and links between general ledger and subledger accounts
• A description of the IT system and electronic books, specifying the software used, parameters, versions, security, backups and access controls
• Principles for recognising revenues and costs based on the accrual and matching principles
• Depreciation of fixed assets and intangible assets — methods, rates and alignment with the fixed asset register
• Foreign currency transactions — methodology for determining exchange rates and balance sheet valuation
• Data quality control procedures — reconciliations, closings, reviews and validations
• Procedure for implementing changes (in line with National Accounting Standard KSR 7) — management resolution, effective date and disclosure method in the notes to the financial statements

JPK_CIT and the Accounting Policy — key challenges

Accounting departments face numerous challenges related to the new obligations coming into force in 2025 and 2026. What makes JPK_CIT particularly demanding is the time required to prepare the chart of accounts, systems, procedures, and to align internal processes and the accounting policy accordingly.

JPK_CIT implementation timeline:

From 1 January 2025
Large entities (tax capital groups, revenue > EUR 50 million). First submission: March 2026.

From 1 January 2026
Medium-sized enterprises (including those already reporting JPK_VAT). First submission: March 2027.

From 1 January 2027
The obligation will apply to all entities keeping accounting books.

Scope of data:

JPK_KR_PD
Accounting books and CIT settlement (general ledger structure, journal, accounts, entries, controls, tax adjustment register – RPD).

JPK_ST_KR
Complete register of fixed assets and intangible assets.

RPD
Classification of tax differences (mandatory from 2026)

The data contained in these structures must remain consistent with the CIT-8 return and the financial statements.

Most common errors and issues:

• incorrect account and tax tag mapping
• lack of breakdown for aggregated accounts
• inconsistent contractor data
• lack of alignment between CIT-8, financial statements and JPK structures
• unprepared ERP systems (missing fields, integrations, XML validation)

From 2026 onwards, contractor data (VAT ID/TIN, country) will be mandatory for almost all entities, and the authorities will be able to easily identify relationships and verify WHT (withholding tax).

Implications for the Accounting Policy

10 steps to compliance — Action Plan

1. Appoint a management board representative and a process owner within the accounting department
2. Conduct an “as-is” audit of the accounting policy against Article 10 of the Accounting Act and JPK_CIT requirements
3. Clean up the chart of accounts — end the practice of using generic “catch-all” accounts
4. Develop a dictionary of tax tags and an account-to-JPK mapping matrix
5. Establish a contractor data management procedure (codes, VAT ID/TIN, country, exceptions)
6. Prepare the ERP system: fields, rules, XML export, change logs, version control
7. Perform test generation of JPK_KR_PD and JPK_ST_KR
8. Implement periodic data quality controls and mapping reviews
9. Organise training for the accounting and IT teams
10. Prepare a change management process in line with National Accounting Standard KSR 7 (resolutions, timeline, disclosures)