A particularly important type is the JPK submitted upon request, which the tax authorities may require during a tax audit or tax proceedings. However, relatively few entrepreneurs know how to prepare for such a request properly. Read this article to learn everything you need to know.

What is JPK?

What exactly is JPK, and who is required to submit it? The Standard Audit File for Tax (JPK – Jednolity Plik Kontrolny) is a standardised set of data generated directly from a taxpayer’s IT systems and submitted to the tax authorities in XML format. Thanks to its standardised structure, the tax authorities can automatically analyse accounting and tax data and identify potential irregularities in tax settlements more efficiently. Poland was not the first country to introduce this solution—similar mechanisms had previously been implemented in, among others, Portugal, France, and Germany. Properly maintained accounting records provide a solid foundation for generating accurate JPK files and minimising risks during tax audits.

The Polish Ministry of Finance provides JPK logical structures covering various types of accounting books and records. In the case of JPK submitted upon request, seven principal structures are currently in use:

• JPK_KR – accounting books,
• JPK_WB – bank statements,
• JPK_MAG – warehouse records,
• JPK_FA – VAT invoices,
• JPK_FA_RR – VAT invoices issued to flat-rate farmers,
• JPK_PKPIR – tax revenue and expense ledger,
• JPK_EWP – revenue records.

The JPK_V7 file is submitted on a recurring basis—by the 25th day of each month—by all active VAT taxpayers, regardless of the size of the business. The remaining JPK structures are submitted to the tax authorities only upon their explicit request. If you have any questions regarding the accuracy of your tax settlements or the scope of your reporting obligations, professional tax advisory services can help clarify them.

JPK upon request – key information

JPK upon request refers to those seven Standard Audit File structures that the tax authorities may request during tax procedures. Such a request may be issued in the course of a tax audit, verification activities, customs and tax inspections, or tax proceedings. Importantly, the obligation may apply not only to the taxpayer but also to the taxpayer’s contractor, provided that the contractor keeps its accounting records in electronic form. It is also worth reviewing any tax reliefs available to you, as these may affect the scope of data included in your accounting records and it is important to understand your rights in this respect.

Once you receive a request, the deadline for submitting the required files is generally no shorter than three days, although in practice it is often set at seven days. In justified circumstances, such as a large volume of data or the absence of the person responsible for preparing the files, you may apply for an extension of the deadline. Ignoring the request or deliberately failing to comply may result in a procedural fine of up to PLN 2,800 and, in more serious cases, fiscal penal liability, including fines that may amount to several million zlotys. If you have any doubts regarding the scope of your obligations, it is advisable to consult specialists—professional legal advisory services can help you assess the risks and determine the appropriate course of action.

How to prepare and submit JPK upon request

The method of preparing a JPK file upon request depends primarily on the form in which your accounting records are maintained. If your records are kept electronically, you may choose from several methods of submitting the data:

• the free Klient JPK WEB application, which enables electronic generation and submission of JPK files,
• the e-mikrofirma application—a tool provided by the Ministry of Finance that enables simplified accounting record keeping and the preparation of selected JPK files,
• a data storage device (USB flash drive or CD/DVD), delivered directly to the tax authority or sent by traditional mail,
• commercial online applications integrated with your accounting software.

The file must be authenticated using a Trusted Profile (Profil Zaufany), a qualified electronic signature, or—where permitted for individuals—authorisation data, including the amount of income reported for the previous tax year. Once the file has been submitted successfully, you will receive an Official Receipt Confirmation (UPO – Urzędowe Poświadczenie Odbioru). If any irregularities are identified, the tax authority may require you to resubmit the data in the correct form. However, JPK structures submitted upon request are not subject to the correction procedure applicable to JPK_V7.

FAQ

What is a JPK declaration and what does it include?

Wondering what a JPK declaration is in practice? This is the commonly used name for the JPK_V7 file, which combines VAT purchase and sales records with the VAT return, replacing the previously separate VAT-7 return and JPK_VAT file. All active VAT taxpayers are required to submit the JPK_V7 on a monthly basis—by the 25th day of the following month—regardless of their VAT settlement frequency.

What is the Standard Audit File for Tax (JPK) obligation and who does it apply to?

What does the Standard Audit File for Tax obligation mean for businesses? Since 1 January 2018, all active VAT taxpayers—from large corporations to micro-enterprises—have been required to maintain VAT records electronically and submit the JPK_V7 file. Taxpayers carrying out exclusively VAT-exempt activities are generally exempt from this obligation; however, exceptions apply, including entities making intra-Community acquisitions of goods or importing services.

What is JPK, and who besides the tax authorities may request it?

Since 1 January 2020, JPK files submitted upon request may be required not only by the tax authorities but also by the President of the Polish Office of Competition and Consumer Protection (UOKiK), who may request such information even from entities that are not direct parties to the transaction under investigation. Refusal to provide the requested data may result in financial penalties of up to 5% of the undertaking’s revenue generated in the previous financial year, capped at the equivalent of EUR 50 million.

Summary

JPK is a tool that the tax authorities are using with increasing efficiency. The number of tax audits involving JPK continues to grow, while the development of advanced analytical tools makes the verification of accounting and tax data faster and more accurate. Understanding how the Standard Audit File for Tax operates, as well as the obligations related to JPK submitted upon request, will enable you to respond efficiently to requests from the tax authorities and minimise the risk of costly penalties. If you would like to ensure that your documentation complies with the applicable regulations and is fully prepared for a potential tax audit, contact KR Group. Our experts will be pleased to support you at every stage of the process.