31 July 2026 is the deadline for the first mandatory submission of JPK_CIT for 2025 by taxpayers covered by the first stage of the new obligations. In practice, this primarily concerns tax capital groups and the largest CIT taxpayers, i.e. entities whose revenue in the previous tax year or financial year exceeded the equivalent of EUR 50 million.
The extension of the deadline to the end of the seventh month after the end of the tax year or financial year gives taxpayers additional time, but it should not be treated as a reason to postpone preparations. JPK_CIT is not simply another year-end form to be completed. It is a data reporting obligation based on accounting books, the chart of accounts, fixed asset records and tax-accounting processes.
Who is covered by the first deadline?
The first reporting deadline generally applies to entities whose tax year or financial year began after 31 December 2024 and which belong to the first group of taxpayers covered by the obligation. These are:
- tax capital groups,
- CIT taxpayers and partnerships without legal personality whose revenue in the previous tax year or financial year, as applicable, exceeded the equivalent of EUR 50 million.
For taxpayers whose tax year coincides with the calendar year, this means that the first JPK_KR_PD file for 2025 must be submitted by 31 July 2026. Where the tax year or financial year differs from the calendar year, the deadline should be determined individually — as a rule, by the end of the seventh month after the end of that year.
What is JPK_CIT?
JPK_CIT is the commonly used name for the new income tax reporting obligations. For taxpayers keeping accounting books, two structures are of key importance:
- JPK_KR_PD — a structure covering accounting books and additional data relevant from an income tax perspective, including account tags and information enabling an analysis of differences between accounting profit and taxable income;
- JPK_ST_KR — a structure relating to the fixed asset and intangible asset register, covering data on assets, depreciation and selected source documents.
In practice, the first reporting for 2025 focuses primarily on the JPK_KR_PD structure. The obligation to submit JPK_ST_KR for the first year has been temporarily limited, which does not mean, however, that taxpayers may disregard the preparation of data concerning fixed assets and intangible assets for subsequent periods.
Key assumptions of JPK_CIT
The most important assumptions of the JPK_CIT include:
- Annual reporting — JPK_CIT is submitted after the end of the tax year or financial year, not monthly.
- Reporting without a request — the taxpayer submits the data by operation of law, similarly to other recurring electronic reporting obligations.
- Data comes directly from the books — the quality of source data, proper bookkeeping and consistency of financial and accounting systems are crucial.
- Account mapping is important — the chart of accounts should allow appropriate accounting and tax tags required in the JPK_KR_PD structure to be assigned.
- JPK_CIT does not replace CIT-8 — the file is analytical and reporting-oriented; it does not eliminate the obligation to file the annual tax return.
- The scope of data will expand — some data for the first year is subject to simplifications or temporary exclusions, but taxpayers should not assume that these simplifications will also apply in subsequent years.
The final days before the deadline – what should taxpayers focus on?
The main challenge with JPK_CIT is not the technical generation of the XML file itself, but preparing the data in a way that allows a correct, complete and consistent report to be generated. Errors in the chart of accounts, missing required counterparty data, inconsistent posting rules or dispersed fixed asset records may only become apparent at the stage of test file generation.
Taxpayers covered by the first deadline should therefore now focus on the final readiness check: verifying account mapping, performing or re-reviewing a test export, reconciling the data with the CIT calculation and financial statements, and confirming responsibility for signing and submitting the file.
What should be done before the first submission?
Before your first submission, it is worth to:
- confirm whether the entity belongs to the group covered by the first reporting deadline,
- determine the correct submission deadline depending on the tax year or financial year,
- verify the chart of accounts and the tags required for JPK_KR_PD,
- check the completeness of counterparty and source document data,
- perform test file generation and technical and substantive validation,
- reconcile the data reported in JPK_CIT with the year-end closing process, CIT-8 and the financial statements,
- confirm who will be responsible for signing and submitting the file.
Summary
31 July 2026 is an important date for the largest CIT taxpayers and tax capital groups. The first JPK_CIT reporting will be a practical test of the quality of accounting, tax and system data. A few days before the deadline, the key issue is no longer implementation planning, but closing the process: file validation, data reconciliation, confirmation of the signing path and ensuring technical readiness for submission. The safest approach is to treat the first submission not as a one-off task, but as part of an ongoing tax reporting process.
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