DAC8 Reporting in Poland: Practical Guide

Poland has a large and growing crypto-asset market and has been developing its regulatory and tax framework for digital assets. The Krajowa Administracja Skarbowa (KAS), Poland's National Revenue Administration, is expected to oversee DAC8 reporting obligations. This guide provides practical information for crypto-asset service providers and other reporting entities operating in Poland.

National Authority

The Krajowa Administracja Skarbowa (KAS), or National Revenue Administration, is the competent authority for tax administration in Poland, including international exchange of information. KAS already manages CRS and FATCA reporting and is expected to be responsible for receiving and processing DAC8 reports. The Ministry of Finance (Ministerstwo Finansow) oversees tax policy and the legislative transposition of EU directives.

Submission Requirements

Poland has been modernising its tax administration infrastructure, and DAC8 submissions are expected to be handled electronically.

• Format: Reports should follow the OECD CARF XML schema as mandated by DAC8. KAS may publish supplementary technical specifications for Polish submissions, potentially building on its existing electronic reporting infrastructure.
• Language: Official tax administration in Poland is conducted in Polish. While the XML data fields should follow international standards, any accompanying documentation and correspondence should be in Polish.
• Submission channel: Poland may integrate DAC8 reporting into its existing electronic tax systems, such as the e-Deklaracje platform or the JPK (Jednolity Plik Kontrolny) system. The exact submission method is to be confirmed by KAS.
• NIP number: Reporting entities will need a Polish tax identification number (NIP - Numer Identyfikacji Podatkowej) for filing.

Transposition Status

Poland must transpose the DAC8 directive into national law by December 31, 2025. The transposition typically involves a legislative act (ustawa) passed by the Sejm (lower house of Parliament) and the Senat (upper house). Poland has had variable experiences with transposition timelines for EU directives. Reporting entities should monitor the Dziennik Ustaw (Journal of Laws) for the publication of implementing legislation.

Local Variations

Poland may introduce specific national requirements:

• Existing crypto tax provisions: Poland taxes crypto-asset income under a flat rate as part of capital gains (przychody z kapitalow pienieznych). DAC8 data may be used to verify compliance with these domestic rules.
• PESEL/NIP collection: Poland uses PESEL numbers for individuals and NIP for businesses. DAC8 due diligence processes should be adapted to collect these identifiers.
• KNF coordination: The Polish Financial Supervision Authority (Komisja Nadzoru Finansowego, KNF) oversees financial markets. DAC8 reporting may be coordinated with MiCA regulatory requirements administered by the KNF.
• Growing market: Poland's large and growing crypto market may lead the authorities to pay particular attention to DAC8 compliance and data quality.

Key Dates

• Transposition deadline: December 31, 2025 (directive must be incorporated into Polish law)
• Data collection begins: January 1, 2026 (reporting entities should start collecting relevant information)
• First reporting period: Calendar year 2026
• First reports due: 2027 (exact date to be confirmed by KAS)

Practical Tips

• Register with KAS: Ensure your entity is properly registered with the National Revenue Administration and has the necessary credentials for electronic filing.
• Monitor the Dziennik Ustaw and Ministry of Finance: The Official Journal of Laws and Ministry publications will contain the transposing legislation and implementing regulations.
• Prepare Polish-language capabilities: Ensure your compliance team or local advisors can handle communications and documentation in Polish.
• Ensure PESEL collection: For Polish reportable persons, ensure your systems can accurately collect and validate PESEL numbers.
• Build on existing JPK experience: If your entity already files JPK reports with Polish tax authorities, consider leveraging that electronic reporting experience for DAC8.
• Engage local tax advisors: Given the specificities of Polish tax law, consider engaging Polish doradcy podatkowi (tax advisors) with expertise in digital assets and international reporting.

Important Notice

This guide provides general information about DAC8 reporting in Poland. Requirements may change as the directive is transposed into national law. The information presented here should not be considered definitive legal or tax advice. Always consult the Krajowa Administracja Skarbowa (KAS) and the Ministry of Finance for the latest official requirements. For specific compliance questions, seek advice from qualified Polish tax professionals.