This obligation will initially apply to CIT taxpayers with revenue exceeding 50 million euros in the previous fiscal year, as well as tax capital groups. A brochure has been published outlining the required logical structure for the accounting book JPK_KR_PD and the fixed assets register. Companies will be required to maintain their accounting records using computer software, and then submit them electronically to the appropriate head of the tax office. The internal financial and accounting systems of entities must be adapted to the requirements in such a way that, starting from January 1, 2025, they can generate accounting records along with specified additional data according to the logical structure.

The implementation of this new obligation has been staggered over time. In March 2026, which is the deadline for submitting the tax return for 2025, taxpayers will be required to submit the first JPK_KR_PD logical structures. From the beginning of the year, obligated entities will need to include only markers identifying accounting book accounts in the logical structure. The contractor identification number, invoice identification number in KSeF, and the amount, type, and nature of the difference between the accounting result and the tax result will only need to be provided starting from January 1, 2026. Other CIT taxpayers required to submit JPK_VAT will be subject to the obligation from December 31, 2025, while other CIT taxpayers and non-legal entity companies will be covered from December 31, 2026.

The Ministry of Finance has included provisions in the regulation to simplify the fulfillment of obligations related to maintaining accounting records. It has been decided to exclude the requirement to submit a VAT identification number (NIP) for individual transactions in the case of entities specified in the regulation. It was also stated that the scope of additional data will not include fixed assets or intangible assets recorded before January 1, 2025, except for the date they are removed from the register. The exclusion of the requirement to submit them will be specified in a separate legal act. It was also clarified that the new obligation does not affect the existing method of submitting CIT returns and declarations.