One example of a regulatory requirement specific to the Polish legal framework is the Standard Audit File. A similar reporting obligation exists in many countries; however, due to differences in tax regulations, solutions implemented in the corporation’s central SAP system cannot be applied in Poland. As a company operating under local law, the Polish branch must report according to the structures required by the Polish Ministry of Finance.
The introduction of the SAF reporting obligation in 2016 clearly illustrates how, despite best intentions, it can sometimes be difficult to remain fully compliant with legislation. The Ministry of Finance gave companies just three months to prepare for the obligation to generate the Single Control File. The clock started ticking, and companies began looking for solutions that would help adjust corporate integrated systems, including SAP, to new requirements. The challenge was considerable, and the situation was made even more difficult by the fact that the final file formats were published at the last minute.
The situation repeated itself in early 2020, when the Ministry of Finance announced far-reaching changes to the SAF structure and, following the announcement of the final version of the JPK_VAT schemas, companies were given less than two months to finalize their work. Ultimately, due to the COVID-19 pandemic, the effective date of the new schema was postponed, but even so, there was still very little time left.
In 2024, the Ministry of Finance imposed an additional annual SAF reporting obligation using the new SAF structures for CIT (JPK_PD): JPK_KR_PD and JPK_ST_KR. It can be expected that these will not be the last changes to SAF. And each of them will require adjustments in SAP.
We are currently witnessing a similar situation with the introduction of electronic invoicing and the National e-Invoicing System (KSeF). In this case, the tax authorities have already postponed the mandatory KSeF implementation date several times. Initially, it was scheduled for 2023. Currently, the effective dates are February 1, 2026, for companies with sales exceeding PLN 200 million in 2025 and April 1, 2026, for all other businesses. At the same time, changes, adjustments, and new logical structures continues to be introduced to the KSeF.
This uncertainty does not promote business stability, and nearly every change to reporting obligations requires modifications to the SAP system configuration.
SAF and KSeF are just two of a long list of Poland-specific legal requirements that need to be taken into account when implementing SAP in the Polish branch of a corporation. At All For One Poland, we have identified more than 50 necessary changes and adjustments to the system across four key areas: Finance, Sales and Distribution, Materials Management and HR.