The Standard Audit File for Tax is a complex collection of electronic data that entrepreneurs will be obliged to send to the tax authorities. The types of Standard Audit File for Tax (SAF-T) that have been published show not only the structure and expected content of the files, but also their format. The regulations introduced by the Act of 10th September 2015 on amending the Tax Ordinance Act (Dz.U.z 2015r. poz.1649) oblige tax-payers to submit their tax books and accounting documents in the form of Standard Audit File for Tax (SAF-Ts).

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The Standard Audit File for Tax is a complex collection of electronic data that entrepreneurs will be obliged to send
to the tax authorities. The types of Standard Audit File for Tax (SAF-T) that have been published show not only
the structure and expected content of the files, but also their format. The regulations introduced by the Act of 10th Sep-
tember 2015 on amending the Tax Ordinance Act (Dz.U.z 2015r. poz.1649) oblige tax-payers to submit their tax books
and accounting documents in the form of Standard Audit File for Tax (SAF-Ts).
This obligation is a new means for the tax authorities to not only decrease the duration and cost of tax audits, but
also to make them more effective. This new approach to tax audits will make it possible to reveal inconsistencies be-
tween the documents and tax statements, expose any irregularities in the submitted data or any inconsistencies with
the data submitted by clients and business partners (so-called cross audits).
What is SAF-T?
The logical types of the different SAF-Ts have been published in the Biuletyn Informacji Publicznej (Bulletin of Public
Information) of the Ministry of Finance. With this new system, tax-payers will be able to send all or some of their tax
books and accounting documents for specific periods. Request for such would, of course, only apply to periods
that have already been settled. More information on the different types of SAF-Ts is available online at
http://www.mf.gov.pl/kontrola-skarbowa/dzialalnosc/jednolity-plik-kontrolny
SAF-T types
The new requirements have already been implemented in big enterprises that process huge amounts of documents
and often enter into transactions with affiliated entities. Gradually though, small, medium, and micro businesses
will also have to adjust to the new regulations. Who needs to be ready to generate Standard Audit File for Tax,
and when, is shown in the timelines on the next page.
Who is obliged to use SAF-Ts, and when?
Accounting
books
Warehouse
operations
Bank
statements
VAT
invoices
VAT registers
(sales and
acquisitions)
Revenue and
expense ledger
Revenue
registry
SAF-T_KR SAF-T_WB SAF-T_MAG SAF-T_FA SAF-T_PKPIR SAF-T_EWPSAF-T_VAT
SAF-Tthe Standard Audit File for Tax

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VAT registers
1st January 2018
1st January 2017
1st January 2017
1st July 2016
MEDIUM
LARGE
1st July 2018
1st July 2018
MEDIUM
SMALL
Upon request from the tax authorities
The remaining SAF-Ts
PKF BPO Consult Spółka z ograniczoną odpowiedzialnością Sp. k.
Without request
from the tax authorities to be submitted monthly by the 25th day of the following month
1st July 2016
LARGE
1st July 2018
MICRO
MICRO
SMALL

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Enterprises that during the past two fiscal
years:
• employed an average of over
250 employees a year, or
• reached a yearly turnover of over EUR
50m and the sum of their assets
exceeded EUR 43*
Who am I?
Enterprises that during the past two fiscal years:
• employed an average of less than 250
employees a year, and
• reached a yearly turnover of less than
EUR 50m, or the sum of whose assets
did not exceed EUR 43m*
Large enterprises Medium enterprises
Enterprises that during one of the past two fi-
scal years:
• employed an average of less than 50 em-
ployees a year, and
• reached a yearly turnover of less than
EUR 10m, or the sum of whose balance
sheet assets did not exceed EUR 10m*
Enterprises that during one of the past two fiscal
years:
• employed an average of less than 10
employees a year, and
• reached a yearly turnover of less than EUR
2m, or the sum of whose balance sheet
assets did not exceed EUR 2m*
Small enterprises Micro-enterprises
* Pursuant to Art.107 of the Act on Economic Freedom, amounts converted to EUR, as specified in the above division of enterprises, are conver-
ted into PLN on the basis of the average rate announced by the National Bank of Poland on the last day of the fiscal year.
The effects of introducing the SAF-T
Introduction of the SAF-T requires major changes in IT systems, but changes in the way accounting books are kept
are not necessary. Therefore, the SAF-T could be introduced during a fiscal year. It is also important to note that
SAF-Ts only need to be generated for periods that have already been settled.
The SAF-T, VAT payers and foreign entrepreneurs
The obligation to send information in the form of SAF-Ts is also valid for entities not having their permanent principal
office in Poland, but that are registered as VAT tax payers in Poland. In this case, for a foreign entity to be correctly
classified as an enterprise its entire business activity should be taken into account – both that conducted in Poland
and abroad. Also, branches of a foreign enterprise located in Poland will be obliged to submit data at the request
of the tax authorities in the form of a SAF-T, the same way Polish entrepreneurs are.
How do I prepare for this?
Since each entrepreneur must themselves identify the date from which they are obliged to begin submitting SAF-Ts,
it is best to begin preparations in advance. Most of all, verify that the IT systems in your company are able to generate
the required SAF-Ts; run an analysis of the software currently in use and if necessary, implement the appropriate new
functions.
PKF BPO Consult Spółka z ograniczoną odpowiedzialnością Sp. k.

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It is important to note that the SAF-T does not only relate to accounting books. In cases of entrepreneurs that outso-
urce their accounting, this may require them to provide several files from several different systems, where JPK_MG
(warehouse) and JPK_FA (VAT invoices) will be provided directly by the entrepreneur, JPK_KR (accounting books) and
JPK_VAT (sales and acquisition registers) will be provided by the accounting firm providing services to the entrepreneur.
JPK_WB (bank statements) will have to be provided by the bank holding the entrepreneur’s bank accounts.
Special attention must be paid by entrepreneurs whose IT systems are based outside Poland, for example at their head
office in another country. In such cases the legislator does not provide for any exceptions, since the obligation to provide
SAF-Ts is imposed directly on the taxpayer, regardless of the type of software used.
When is a SAF-T required?
The legislator has determined two types of penalties. The first is for failing to provide data as a SAF-T at the request
of the tax authorities during any tax procedures being conducted. The second is for failing to provide data as a SAF-T
for the sales and acquisitions register.
Sanctions and penalties
2 800 PLN
Penalty for breach
of order
17 760 000 PLN*
Fine
Penalty for an unjustified refusal to submit documents within the given deadline, if the
obligation to provide such documents is established directly by the legal regulations.
Penalty for obstructing or thwarting the performance of official duties, and in parti-
cular failing to provide a book or other documents related to the business activity.
This penalty is also for damaging, destroying, hiding, removing or rendering
a book or other documents useless
It should also be noted that the legislator imposes a more severe penalty for providing false information, namely
up to 240 daily rates, than in cases of untimely delivery or failure to provide tax information to the competent authority –
in these cases, the fine is up to 120 daily rates (pursuant to Art. 80 § 1 of the Penal and Fiscal Code).
SAF-T
At the requ-
est of the tax
authorities
During a
fiscal /
tax audit
During tax
procedures
For
auditing
purposes
1
2 3
4
*up to 720 daily rates

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Summary
PKF BPO Consult Spółka z ograniczoną odpowiedzialnością Sp. k. is a part of the PKF Consult Capital Group in Poland, which itself is a member firm
of the PKF International Limited family of legally independent firms and does not accept any responsibility or liability for the actions or inactions of any
individual member or correspondent firm or firms.
PKF BPO Consult Spółka z ograniczoną odpowiedzialnością Sp. k.
Joanna Brzezińska
Łódź Branch Director
Tel.: +48 502 387 525
joanna.brzezinska@pkfpolska.pl
Ewa Sąsiadek
Opole Branch Director
Tel.: +48 510 125 262
ewa.sasiadek@pkfpolska.pl
Anna Stankiewicz
Director of External Accounting
in Warsaw
Tel.: +48 609 208 400
anna.stankiewicz@pkfpolska.pl
The changes introduced by the Polish legislator will improve the quality of the information provided to the tax audit
authorities. However, the various types of Standard Audit File for Tax are not the last change for which
entrepreneurs sho-uld prepare. At the moment, preparatory works are being carried out to introduce two additional
types of SAF-T, for excise and fiscal cash registers. As announced by the Minister of Finance, work has also begun
on introducing a Central Register of Invoices, in order to more closely monitor Value Added Tax.
In view of both the existing and planned regulations, it is vital to adapt your company software in the right way and
at the right time, and to train your staff, so as to avoid severe sanctions and penalties. We are always happy to help
in case you have any questions, and you can also visit the website of the Ministry of Finance and read the respecti-
ve legal regulations there.
THE SAF-T IS A REAL CHALLENGE FOR ENTREPRENEURS
ANY QUESTIONS?
Contact our experts