PolandPolska Izba Biegłych Rewidentów (PIBR)
2026 audit reports gain mandatory income-tax-report filing statement
Auditors of 2026 financial statements must state whether the audited entity had to file an income-tax report with the court register and whether it did — a new Article 83(3)(16a) duty for every audit.
By Taxxa AI OyPublished 7 November 2026
Industry: Accounting, bookkeeping and auditing activities; tax consultancy
Statutory auditors signing reports on 2026 financial statements face a new mandatory sectionPibr: information on whether the audited entity had a duty to file an income-tax report (sprawozdanie o podatku dochodowym) with the National Court Register (KRS)
Pibr and whether it performed that duty
Pibr. The Polish Chamber of Statutory Auditors (PIBR) announced on 6 November 2026 that the requirement, flowing from Article 83(3)(16a) of the audit act
Pibr, applies for the first time to reports on the 2026 year
Pibr.
The duty attaches to every audit of financial statements, not only to statutory auditsPibr. The auditor looks at the financial year preceding the audited year and determines whether the entity fell within Article 63m(1) or Article 63n(1) of the Accounting Act: an ultimate parent or standalone entity with revenues above PLN 3.5 billion in each of the last two financial years, or a Polish subsidiary (other than a micro or small entity) or large branch of a group headed outside the European Economic Area, with consolidated or standalone revenues above EUR 750 million in each of the last two years
Pibr. Where the entity sits outside that scope, the auditor inserts no information at all. Where it sits inside, the audit report states the entity's duty to file the income-tax report with the competent court register
Pibr and whether the entity filed it
Pibr — including an explicit statement where no filing duty arose because of legal form or an exemption.
The auditor's statement does not assess the content of the income-tax report; it records only whether the filing duty existed and whether it was performed. Under the Accounting Act, the report itself is filed with the court register within 12 months of the balance-sheet date and published on the entity's website for at least five years.
PIBR's accompanying communication offers variants of the auditor's determination together with sample wording for the new audit-report section. It stresses that the material is auxiliary only: an auditor may discharge the statutory duty in a different way where that is consistent with legislation and professional standards, and every case calls for an assessment of the concrete circumstances, possible legal analysis and the exercise of professional judgment.
The requirement rests on Article 83(3)(16a) of the ustawa o biegłych rewidentach, firmach audytorskich oraz nadzorze publicznymPibr, in force since 22 June 2025
Skwp, read with Articles 63m and 63n of the ustawa o rachunkowości.
For each 2026 audit, determine whether the audited entity fell within Article 63m(1) or 63n(1) for the preceding year and insert the required filing-duty statement — or record that no statement is needed.