SAF-T for Poland and SAP



From 1st July 2016 onwards it is required to provide SAFT-PL files (in Polish: “Jednolity Plik Kontrolny” or “JPK”) in XML format on request of the PL Tax authorities.


Filing SAF-T will be mandatory for large taxpayers: employ more than 250 people or 50 million EUR sales revenue irrespective of whether they are established in Poland or not.

Per 1st July 2018 this extended to taxpayers with more than 9 employees or 2 million EUR sales revenue. Foreign businesses not having a branch and/or fixed establishment but that are registered for VAT in Poland fall within the scope of the above reporting requirement when above conditions are met.

On 19 May 2016 the Upper Chamber of the Polish Parliament passed a bill on the amendment of provisions of the Tax Ordinance and of some other acts. According to the bill adopted by the Parliament, the obligation to generate VAT reports in a SAF-T data format and their monthly reporting to the tax authorities will apply initially only to the largest enterprises for each month begun on or after 1 July 2016.

According to new regulation It means that Large Enterprises will be obliged to file VAT reports in the SAF-T data format already on 25 August 2016. Thus, Large Enterprises will be obliged to submit in monthly period VAT register in SAF-T format (according to JPK_VAT structure 4 – VAT register) even if the VAT reporting period is quarterly.

Taxpayers will be obliged to submit the SAF-T format:

  • on request in the case of a preliminary tax inquiry, a tax audit and tax proceedings;
  • monthly mandatory – with respect to the VAT sales and purchases records only (Article 109(3) of the Value Added Tax Act of 11 March 2004 (VAT records) by submit monthly a SAF-T file that contains VAT sales and purchase records


The first requests to submit audit files at their discretion will likely take place September 2016.  The monthly VAT reports on 25 August 2016.

Not complying with this obligation will not only negatively affect the position of taxpayers during a tax audit but also result in unforeseen tax costs as penalties will be levied. 

‘Final' version of the logical structures of the Standard Audit File (SAF) was published by the Ministry on 9 March 2016 including FAQ.


Besides introduced now in Poland similar EU obligations exist already in Portugal (2013) Luxembourg (2013), Austria (2009), France (2014), Lithuania (2015). More and more tax administrations around the world are implementing electronic auditing of a business’ financial records and systems.


SAP and SAF-T Poland


SAP developed currently only an extraction tool for SAP ECC 6 and higher version. The generation of the SAFT-PL XML files is not included. Certain companies use “older versions” of SAP (SAP R/3) and will not be supported by SAP.


Based on SAP's OSS notes, SAP provides only at the moment a functionality for gathering and downloading some transactional data. However, it is not the complete set of data required and the creation of the SAF-T file for the tax authorities is also not included.

The functionality will also only be available for companies established in Poland and not for companies with a foreign Polish VAT registration. In order to be able to comply with the requirements and provide the XML file on request in time, tooling needs either to be developed or purchased.


Our solution


A SAFT-PL tool that already works for Portugal that includes also strategy for downloading the relevant data from SAP  for older SAP versions.

The basic design for a workaround solution is to extract the raw source data from the relevant SAP tables and use software tools to load the relevant data from the source SAP tables, perform additional mappings and data preparations and create the required XML files.


We offer 3 solutions:


  1. A software application called Audit Command Language (ACL). This software is commonly used by auditing firms, tax authorities and internal audit departments. The process will be that the client will download the data from SAP and make it available to the Phenix. Phenix will then generate the XML files and some control reports and provide these files and reports available to client for submission.
  2. A tool in MS Access in combination with a specific user interface for extracting the data from SAP. The result is a full in-house solution for the client.
  3. New: A SAP add-on solution

In-house tool further explained


A MS Access executable delivered with cockpit functionality. In this cockpit the user could select the data that needs to be downloaded from SAP, add required master data and create the SAFT XML files.

It will be installed locally on a personal computer with the advantage that almost no adjustments are necessary within the accounting system SAP. Special characteristics of posting data (e.g. usage of document types) can be added manually and data extraction can be saved locally for audit trail purposes.


Why our bolt-on solution


  • Companies consider our solution simply a better fit as it is expected that the Polish requirements might change regularly
. A SAP add-on solution due to own internal IT change management processes can cause delays during first implementation or when new requirements are issued by the Polish authorities
  • We have been able to amend our solution to new requirements including testing within a week (based on our SAF-T PT experience)

  • The extra advantage is therefore reducing scarce IT resource time and continue to meet requirements going forward

High level design



Above process is based on our proven tool developed for the generation of the SAF-T files for Portugal.


Generic SAFT PL Functional design (JPK VAT+ ACL)



Why our SAF-T SAP Add-on


We can offer a SAP add-on solution (ABAP) at a fixed all inclusive fee.

To establish synergies we have setup a joint venture initiative with a global development partner of SAP and leading software company in the area of e-invoice, e-bookkeeping, e-archive, e-ticket and such SAP add-ons in Poland. This company provides SAP certified add-ons for legal compliance to a large number of global well-known companies.

*All inclusive : Implementation, training and 1 year of free support and maintenance for bug-fixes & legal updates.

  • Runs over SAP
  • User friendly with single user interface (SAP)
  • Easy to install by external SAP transport
  • Easy to maintain by upgrades via transport files
  • Has its own global SAP namespace so there is no effect on SAP standards and is not affected by SAP upgrades
  • Standard SAP authorizations used
  • Open source code as ABAP programming language
  • Vendor independent
  • One year free maintenance service including bug-fixes & upgrades according to legal compliance


Detailed information about SAF-T compliance and planning




Take aways 

Anticipate what users would want

We combine technical knowledge with industry understanding and knowhow of technologically advanced tools and methodologies available in the market or developed by ourselves.

What do we like to achieve

  • Focus on tax processes that could be improved
    • Manual process: same data requests are made by different stakeholders
  • As Is assessment
  • Anticipate future changes and the data needed
    • What are tax trends?
    • What is happening locally and what should be considered across jurisdictions where you operate?
    • Anticipate new stakeholders and their data needs or requests (internal and external)
  • Define scope and actions for short, mid and long term
  • Write business case for change
  • Realize sponsorship for implementation

‘As is’ assessment, actions and business case

  • What tax data is requested and by whom?
  • What tax process can be improved and what can be automated?
    • CIT, VAT, tax data warehouse
  • What is the Return on Investment?
    • Hard saving: process improvement
    • Meeting (new) tax requirement
  • What systems are in use: SAP, Oracle, etc
    • By which entities?
  • How many end-use computing tools (e.g. excel spreadsheet) do we have?
  • How do we avoid an ad-hoc solution?
    • Understand the bigger picture
    • Real problem and not the symptom

Risk and reward

Technology-related tax risk: understand and address the potential harms and benefits of (new) technology.

Technology tools & systems integration

Ascertaining proper IT support for ensuring efficient, timely and reliable reporting.

Change and project management

VAT should be considered in every aspect of the process, from concept through completion and beyond. Managing by design — looking at any process or transaction from end to end and factoring in all the requirements and controls essential to designing and optimizing a compliant VAT process.

Effective communication and teaming

We speak the language of the business and IT and no translation is needed.

Set up a project plan

  • Set up a project charter that will take effect preferable during feasibility but ultimately during design
  • Write a business case and problem statement
  • Define scope of the project
  • Define objectives and goals of the project
  • Involve stakeholders and define priorities
  • Set measurable milestones
  • Ensure that the right sponsors provide buy-in.
  • Identify (project) risks and how to manage them
  • Jointly validate and refine the project plan and develop a roadmap to success
  • Hold regular meeting to track progress of the various work streams

From concept through completion and beyond

VAT should be considered in every aspect of the process, from concept through completion and beyond.

Managing by design

Looking at any process or transaction from end to end and factoring in all the requirements and controls essential to designing and optimizing a compliant VAT process.

Global tax environment is in a state of fast change

The key to success in the management is the ability to translate tax knowledge into workable business processes.

Risk: a domino-like effect

With indirect taxes intertwining through the day- to-day operations of a company—raising sales invoices, moving inventory, paying suppliers, collecting cash—indirect tax risk can have a distinct and domino-like effect on the commerciality of an organization.

Tax audits and new technology

More than 80% of businesses are still using spreadsheets to manage their VAT compliance in at least one jurisdiction in which they operate, despite tax authorities around the world investing in better tools.

OECD's Standard Audit File for Tax Purposes

The SAF-T standard, originally created by the OECD (similar as BEPS), is intended to give tax authorities easy access to the relevant data in an easily readable format for both corporate income tax as VAT.

What if there are glitches in your data, input errors, empty fields, awkward descriptions in fields or apparent inconsistencies?