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New digital obligations for businesses: KSeF, JPK CIT and emerging compliance challenges

In recent months, companies operating in Poland have been confronted with growing challenges related to the digitalisation of tax, invoicing, reporting, and communication processes with public administration. administration. Although these areas may appear to concern only accounting departments, their impact goes far beyond traditional finance functions.

Accounting in the era of digitalisation

The perception of accounting and tax obligations has changed significantly. These processes can no longer be viewed solely as the responsibility of an internal accounting department or an external service provider. New digital obligations increasingly affect the way the entire organisation operates. Issues such as responsibility allocation, document and data workflows, and internal process design have become more important than ever.

As a result, companies must:

  • adapt their IT systems,
  • ensure employees have access to government portals and reporting tools,
  • secure replacement coverage for key personnel while maintaining data security.

This means that handling accounting‑related obligations is no longer limited to finance teams. It also requires active involvement and efficient organisation across management, administration, IT departments, and internal process owners.

Not only KSeF and JPK CIT – the expanding list of digital accounting obligations

Today, the integration with the National e‑Invoicing System (KSeF) appears to be the most prominent change. While it remains a critical shift, companies must not overlook additional obligations that are already in force or will soon become relevant.

The recently implemented or soon‑to‑be‑implemented requirements include: JPK CIT, e-Delivery system, CbCR reporting. Each obligation has its own rules, deadlines, and involves different areas of the organization, not just finance.

Looking further ahead, companies must also monitor EU‑level initiatives. A key example is the VAT in the Digital Age (ViDA) package, which introduces near‑real‑time reporting of intra‑EU transactions and extends e‑invoicing rules across the European Union. The objective is to reduce VAT gaps, counter tax fraud, standardise reporting, and align processes with modern business realities.

 

Another measure increasing financial transparency is the upcoming requirement to include KSeF invoice numbers in bank transfers. This change will directly link payments to invoices, enhance automation in inter‑company settlements, and allow tracking the full transaction cycle, from invoice issuance to payment.

Accounting digitalisation in the EU context

It is important to emphasise that Poland is not alone in implementing digital solutions. Countries such as Italy, France, and Germany are also developing their own e‑invoicing and tax reporting systems. Therefore, companies operating across borders must also monitor EU‑wide regulatory timelines.

It is also worth highlighting that although Poland is implementing digitalisation in line with the direction set by ViDA, it is doing so more broadly and faster than many other EU countries. As a result, major reporting and settlement changes are occurring nearly simultaneously. The more digital obligations coexist at the same time, the harder it becomes to treat each as a stand‑alone requirement. Increasingly, companies need an integrated approach, aligning processes and coordinating activities across the entire organisation.

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Who Is responsible for meeting accounting obligations?

Despite the progressive digitalisation, responsibility for the company’s accounting remains unchanged. It lies with the “head of the entity,” which in capital companies is typically the management board. This responsibility is not merely organisational or civil—it may also carry criminal or fiscal‑penal consequences.

Moreover, this obligation does not disappear when accounting is outsourced or handled by internal specialists. It makes no difference whether the work is performed by an external accounting firm, a chief accountant, a shared service centre, or a finance team located abroad.

In practice, this means that company management must understand: which obligations apply to the company, what deadlines exist, who internally is responsible for each task. A lack of this knowledge does not release management from liability. The consequences of non-compliance extend beyond the risk of fiscal penalties. Financial institutions often condition lending decisions on timely financial statements, while delays in reporting can damage relationships with business partners and counterparties.

A new model of tax audits in the digital world

Thanks to ongoing digitalisation, tax authorities now have much faster and broader access to data than ever before. Currently, taxpayers are selected for audits not only based on tax returns, but also on: e-financial statements, notarial deeds, banking reports, data from sales platforms and information from many other sources.

As a result, tax inspections are increasingly less random. Officers no longer act “in the dark”. They rely on algorithm‑based indicators analysing and cross‑checking digital data from multiple sources. Advanced analytical tools, using data from KSeF and JPK CIT, will further increase the effectiveness of these assessments. Companies must therefore expect more frequent and more precise audits.

From a management perspective, the key priority today is not only implementing new tools, but most importantly ensuring that the organisation has clearly defined:

  • How does information flow within the company?
  • Who has access to specific systems?
  • Who is responsible for each obligation?
  • Does internal control operate effectively?
  • Are identified irregularities corrected on an ongoing basis?

 

The digitalisation of taxes and reporting is not a one‑time project. It represents a permanent transformation of the operating model of tax administration and therefore of taxpayers as well. New obligations will continue to emerge, each requiring not only the right tools, but also well‑functioning internal processes. The sooner an organisation treats this area as strategic rather than purely technical, the lower the risk of mistakes, delays, and potential sanctions.

Further guidance and practical insights on key accounting obligations will be presented in upcoming parts of the “New digital obligations in the company” series on the Grant Thornton website.

Read also:

KSeF, JPK CIT and emerging compliance challenges – frequently asked questions

Who is responsible for fulfilling accounting and tax obligations?

Responsibility always lies with the “head of the entity,” which in companies typically means the management board. This accountability remains in place even when accounting is handled by external firms, an internal chief accountant, or foreign shared‑service centres.

What risks does a company face if it neglects digital accounting obligations?

Beyond fiscal penalties, companies may experience delays in financing, loss of trust from business partners, and an increased likelihood of audits triggered by data analysis from multiple sources to which tax authorities now have rapid access.

Which digital obligations must companies take into account today?

Not only KSeF, but also JPK‑CIT, e‑Delivery, CbCR, and parallel reporting processes. Each obligation has its own deadlines and requirements and involves different teams across the organisation.

What are the biggest challenges companies face in the digitalisation of accounting?

The most frequently cited challenges include adapting systems, organising and cleaning data, managing user permissions, increasing reporting demands, and ensuring data consistency across KSeF, JPK and the accounting books

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