Standard Audit File for Tax - what is it and who is required to submit it?


From January 1, 2018, all, even the smallest entrepreneurs, must submit different SAF structures. It is a Standard Audit File in various versions, prepared by the Ministry of Finance. Some of the SAF structures should be submitted monthly, and some of them apply only to active VAT payers. Let's get to know the structure of the Standard Audit File.

What is the Standard Audit File?

The Standard Audit File for Tax is the Polish version of SAF-T (Standard Audit File for Tax), an IT solution developed by the Organization for Economic Cooperation and Development. The purpose of this institution is to improve the functioning of tax authorities, accelerate settlements and prevent incorrect tax settlements. The Uniform Control File documents the sale of goods or services of the entrepreneur and the purchases made by him, so that the VAT settlement is simple and uncomplicated. All registered taxpayers on goods and services are required to submit JPK. From October 2021, the JPK_VAT file, which was introduced first, was replaced with a new, more extensive JPK structure, the so-called JPK_V7 or called JPK_VAT with the declaration. This nomenclature is related to the fact that the JPK_V7 file replaced both the JPK_VAT file in the original structure as well as VAT-7 declarations and VAT-7K declarations.

If the entrepreneur benefits from a subjective or objective exemption and is not obliged to pay VAT, he does not have to send JPK_V7.

How to send a JPK?

A significant part of entrepreneurs use the help of accountants and accounting offices in their daily activities, and these entities relieve their clients in sending SAF-T. If the entrepreneur settles on his own, he can generate and send SAF-T in various ways:

  • using the e-microfirma application;

  • using the JPK 2.0 Client program;

  • with the help of another accounting program that handles the JPK shipment, e.g.;

Entrepreneurs operating in the form of sole proprietorship can use the e-microforma application. The application allows you to issue VAT invoices, book invoices and prepare VAT settlements. The application also generates and sends JPK.

Importantly, sending the SAF requires authentication of the entrepreneur's identity. The entrepreneur can do this by:

  • ePUAP trusted profile;

  • qualified electronic signature;

  • the use of authorization data, including the amount of income.

Various types of JPK files

Currently, there are eight different types (structures) of SAF-T:

  1. JPK_KR: applies to the entrepreneur's accounting books, also in the field of income tax;

  2. JPK_WB: bank statement documenting transactions made on the entrepreneur's account;

  3. JPK_MAG: warehouse records, presenting the movement of goods in the warehouse, their releases and receipts;

  4. JPK_V7: records of purchases and sales of goods and services made by the entrepreneur;

  5. JPK_PKPiR: tax revenue and expense ledger;

  6. JPK_EWP: records of revenues intended for taxpayers paying a lump sum;

  7. JPK_FA: records showing sales invoices, containing the exact description of each transaction made;

  8. JPK_FA_RR: records including VAT RR invoices.

The entrepreneur sends JPK_V7 by the 25th of each month. It is the only obligatory JPK file. If the shipment date falls on a Saturday or a holiday, then JPK should be submitted on the next business day. Even if the entrepreneur settles quarterly, he must send JPK every month.

The entrepreneur is obliged to send JPK_V7 without the request of the tax authorities - it is the entrepreneur who must remember to comply with the statutory deadlines.

If the entrepreneur suspends the activity, he will not be obliged to send JPK_V7. The only exception to this rule is the situation in which the entrepreneur has to complete the VAT register (e.g. due to the purchase of goods during the suspension of activity or suspension of activity in the middle of the settlement period) - in this case, the taxpayer is obliged to submit JPK_V7.

Other JPK file structures are submitted to the office only at the request of the office. There is no need to generate them every month or send them voluntarily to the office.

The trader will receive a message about any irregularities in the file

Tax authorities regularly control the correctness of JPK_V7 submitted by entrepreneurs. This software automatically compares the SAFs submitted by taxpayers and analyzes inconsistencies (e.g. discrepancies as to the amounts in SAF-T of contractors) in the data sent.

If there are discrepancies in JPK_V7, the entrepreneur will receive an e-mail from the address or a text message to the telephone number provided by him in the identification application.

If there are any irregularities in the JPK_V7 file, the entrepreneur will receive an automatic e-mail or text message notification. The message will only contain a notification that any irregularities have been detected in the uploaded file. In this case, the entrepreneur will have to submit the JPK_V7 correction or possibly contact the tax office to determine what is the source of the non-compliance. If the taxpayer fails to make a correction and does not take steps to clarify the matter, he or she runs the risk of paying interest for late payment of the tax and undertaking checks by the tax office.

An inattentive entrepreneur is threatened with a fine

Failure to submit SAF-T may result in prosecution of the entrepreneur. In the event of a reduction of the tax due by an amount lower than PLN 10,000.00, failure to meet this obligation will be an offense, exceeding this amount will be a crime. Pursuant to Art. 61a of the Fiscal Penal Code:

§ 1. Who, contrary to his obligation, does not send the ledger to the competent tax authority or sends it unreliable, shall be liable to a fine of up to 240 daily rates.

§ 2.In the event of a minor offense, the perpetrator of the offense specified in § 1 shall be fined for a tax offense.

§ 3. The penalty specified in § 2 is also subject to the one who sends the book late or defective.

The amount of the fine is dictated by both the statutory limits and the life and financial situation of the perpetrator. It is worth remembering that penal and fiscal liability may result not only in not submitting SAF, but also providing untrue information in the file or failure to meet the deadline for sending SAF-T, as well as failure to submit SAF-T at the request of tax authorities.

If the JPK_V7 file is submitted after the deadline, the so-called active regret to protect against possible sanctions for failure to comply with reporting obligations on time.