The end of the year is an ideal time for foreign investors to conduct a comprehensive review of their Polish operations. This checklist covers the key legal, tax, and compliance areas that require attention before entering 2026. A systematic approach now can prevent costly surprises and ensure your business starts the new year on solid ground.

1. Corporate Governance and KRS

Your company’s registration data must be current and accurate. Polish law requires prompt updates to the National Court Register (KRS).

• Verify that all KRS data is up to date (management board, supervisory board, shareholders, address)
• Check if any changes require registration (capital increases, amendments to articles of association)
• Confirm all beneficial owners are correctly registered in CRBR (Central Register of Beneficial Owners)
• Review management board members’ terms and plan renewals if needed
• Ensure company representation rules are clear and documented

2. Tax Compliance

Tax obligations in Poland require careful year-end planning. Missing deadlines or failing to meet documentation requirements can result in significant penalties.

Corporate Income Tax (CIT)

• Review advance CIT payments and adjust if necessary for Q4
• Verify eligibility for 9% CIT rate (small taxpayer status)
• Assess potential benefits from Estonian CIT regime for 2026
• Review IP Box eligibility for intellectual property income
• Check R&D relief documentation completeness

VAT

• Reconcile VAT records with JPK_VAT filings
• Verify split payment compliance for mandatory sectors
• Check White List verification procedures for significant payments
• Prepare for KSeF (mandatory e-invoicing) implementation

Withholding Tax (WHT)

• Review certificates of residence for foreign contractors
• Verify beneficial owner status for treaty benefits
• Check if pay-and-refund mechanism applies to any payments
• Prepare IFT-2R annual information on foreign payments

3. Transfer Pricing

Transfer pricing documentation requirements are extensive in Poland. Non-compliance can result in penalties up to PLN 720,000.

• Identify all controlled transactions exceeding documentation thresholds
• Prepare or update Local File documentation
• Obtain Master File from parent company if applicable
• Review transactions with tax haven entities (special thresholds apply)
• Verify arm’s length pricing for intercompany services and loans
• Prepare TPR-C form submission (deadline: end of 11th month after fiscal year)

4. Employment and HR

Labour law compliance protects your company from employee claims and regulatory penalties.

• Review employment contracts for compliance with current regulations
• Check work permit validity for foreign employees (apply for renewals 3 months ahead)
• Verify correct classification of contractors vs. employees
• Update internal policies (remote work, anti-discrimination, whistleblowing)
• Plan for minimum wage increase effective January 2026
• Review ZUS contribution basis and adjust payroll accordingly
• Confirm mandatory training records are complete (OHS, first aid)

5. Data Protection and Compliance

GDPR enforcement in Poland has intensified. Regular compliance reviews are essential.

• Review data processing agreements with all processors
• Update Records of Processing Activities (RoPA)
• Verify international data transfer mechanisms (SCCs, adequacy decisions)
• Check cookie consent and privacy policy compliance
• Conduct data retention review and delete expired data

6. Contracts and Commercial Matters

Year-end is the time to review key commercial relationships and contractual obligations.

• Review contracts expiring in Q1 2026 and initiate renewal negotiations
• Check automatic renewal clauses and termination notice periods
• Verify insurance policies coverage and renewal dates
• Review lease agreements for any required notifications
• Confirm bank guarantees and letters of credit validity

7. Financial Reporting

• Prepare year-end inventory count procedures
• Review provisions and accruals for completeness
• Confirm audit engagement if required (thresholds review)
• Plan annual financial statements preparation timeline
• Review intercompany balances and plan reconciliation

Key Deadlines for 2026

• January 20, 2026: Monthly advance CIT payment for December 2025
• January 31, 2026: Annual PIT-4R, PIT-8AR submissions
• February 28, 2026: IFT-2R submission (WHT information)
• March 31, 2026: CIT-8 annual return (calendar year taxpayers)
• June 30, 2026: Annual financial statements filing with KRS
• November 30, 2026: TPR-C transfer pricing information (for 2025 fiscal year)

Conclusion

This checklist provides a framework for year-end compliance review, but each company’s situation is unique. We recommend engaging with qualified legal and tax advisors to address specific circumstances and ensure full compliance with Polish regulations. Starting the new year with all matters in order allows you to focus on what matters most: growing your business in Poland.

Need assistance with your year-end review? Contact our team for a comprehensive compliance audit tailored to your company’s needs.