During the most recent meeting of the Scientific Council at the Office of the Ombudsman for Small and Medium-Sized Enterprises, Paweł Kossecki presented on the topic of the JPK-CIT/PIT reporting requirement as it applies to the SME sector.
The Council concluded that ''the anticipated benefits of tightening the tax system in the SME sector are not commensurate with the amount of work that small business owners must put into preparing for these reporting obligations.''
There is a clear negative trend affecting small accounting firms. Small companies operating in this industry may not be able to meet the challenges posed by the ever-increasing number of new reporting obligations.
It is also worth noting a certain disparity in terms of taxpayer rights protection and access to technology: ''For financial reasons, micro-entrepreneurs cannot afford to use sophisticated IT tools with integrated analytical modules. In contrast, tax authorities, using systems supported by artificial intelligence, will be able to very quickly identify irregularities in accounting records, initiate audit procedures, and then issue decisions largely based on automated analysis.'' While tax authorities will have access to a large dataset and the ability to analyze it efficiently, small business owners will continue to struggle to adapt to the changes.

This also raises another important issue, as the implementation of new technological systems carries the risk of taxpayers making technical errors. In its communication, the Council highlights the need to introduce appropriate regulations in this regard, particularly to distinguish between errors made unintentionally—resulting from the process of implementing and learning new technologies—and intentional errors resulting from the fraudulent maintenance of records.
Without such a distinction, verification algorithms may treat all irregularities in the same way, regardless of the taxpayer’s intent. This could result in an increase in the number of audits and more frequent imposition of penalties.
In light of these issues, the Scientific Council at the SME Ombudsman’s Office has formulated the following recommendations:
- ensuring protection for the smallest entities (limiting obligations or applying exemption thresholds),
- simplifying the language (in instructions and systems),
- support for individuals without advanced IT skills (practical assistance for those entrepreneurs who need it most),
- guaranteeing sufficient time to implement new solutions (taking into account companies’ ability to adapt to the new situation),
- applying the principle of proportionality (the scope of obligations must be justified by a tangible impact on state revenues while respecting the rights of entrepreneurs).