Changing accountants for a Polish sp. z o.o.: checklist

Changing accountants for a Polish sp. z o.o. means transferring complete accounting records, assigning responsibility for filings and updating registrations and access rights. Agree a handover date, collect the records against a list and reconcile balances before the first reporting period with the new firm. An invoice folder alone is insufficient.

Information checked on 13 November 2026. This guide concerns a Polish limited liability company keeping full accounting books. The checklist is a practical handover plan to adapt to the company’s activities, employees, taxes and engagement terms.

Must you wait until the end of the year?

You can change accounting firms during the year, subject to the notice period and other terms of your agreement. A change of service provider is not itself an event requiring the books to close under Article 12 of the Polish Accounting Act. The company’s accounting history continues.

The first day of a month can be a convenient operational starting point because it divides routine work clearly. A January handover still leaves work for the previous year: corrections, the annual tax return and financial statements. Record who will complete each task and the agreed fees.

The management board does not transfer all its responsibility with the files. Article 4(5) of the Act retains the entity manager’s responsibility for accounting obligations, including supervision, even when particular tasks are entrusted to another provider. Appoint someone within the company to accept the handover and confirm the list of missing items. Our separate guide covers choosing an accounting firm for a Polish company.

What should both accounting firms agree?

Before giving notice, read the rules on delivery, notice periods, data release and additional charges. Agree file formats with the incoming accountant and check whether the records can be reconstructed. A promise to accept documents does not establish that an export from the previous software can be read.

Use one task list with the reporting period, named owner and completion date. Assign at least these responsibilities:

• posting the final month handled by the outgoing firm;
• preparing, reviewing and submitting JPK files and tax returns;
• checking acceptance and handing over official receipts, known as UPO;
• correcting earlier reporting periods;
• payroll, ZUS and employee records, where applicable;
• annual reporting, financial statements and access to the archive.

Calculating tax, submitting a return and paying the tax are separate actions. Identify who approves the amount and who makes the transfer. Changing accountants does not extend statutory deadlines. If a task has no clear owner, resolve that gap explicitly rather than assuming the other firm will do it.

Which records should you collect?

Request a transfer list showing the period, format, export date and whether the package is final. Test that electronic files open. For paper records, confirm the folders and dates covered. The handover record should also identify missing items and when they will follow.

Add the relevant schedules and unresolved issues if the company holds inventory, trades in foreign currencies or uses Estonian CIT. Do not bundle bank passwords or private signing keys with the records. Give the incoming team its own access with the permissions needed for its work.

How do you reconcile balances? A December example

Suppose the incoming firm takes over routine bookkeeping on 1 December. The outgoing firm completes November and provides reconciled records through 30 November. A separate agreement identifies who submits November’s JPK in December. This is an organisational example, not a legally required handover date.

The receivables schedule shows PLN 12,300 due from a customer. The company issued an invoice for PLN 12,300 but received PLN 5,000 on 27 November. If that payment has not been allocated, the actual open receivable is PLN 7,300. Transferring an unexplained PLN 12,300 balance carries the error forward and may lead to an unnecessary payment demand.

Before accepting the data, compare:

1. each bank account balance with its statement at the handover date;
2. receivables and payables with the list of unpaid documents;
3. imported turnover and balances with the approved source schedule;
4. advances, loans and shareholder balances with the documents and payments;
5. tax registers with the latest submitted files and corrections.

Do not clear differences with an arbitrary balancing entry. Record the cause, supporting document, correction and reviewer. Keep the original data and the final package. If a later export replaces an earlier file, label the replacement clearly so that neither accountant works from the wrong version.

Does the company need to update NIP-8?

A sp. z o.o. registered in KRS updates its supplementary information, including accounting firm details, through NIP-8, rather than CEIDG. ZUS states a seven-day deadline for changed information. Check that the recorded location of accounting documentation is also current.

Separately, Article 11a of the Accounting Act applies when books are kept outside the entity’s registered office or place of management. It requires notification of their location within 15 days of handing over the books and availability for inspection. Agree how both obligations will be met. The 15-day provision does not extend the NIP-8 update deadline.

Keep the submitted update and its acceptance confirmation. In the handover record, name the person preparing the update, the authorised signatory and the person checking that the information was correctly delivered.

What happens to authorisations and KSeF access?

Ending the engagement does not replace a review of every authorisation. List the people and systems involved, then agree when each permission should end.

• Electronic tax returns: check UPL-1 for the incoming representatives. Use OPL-1 to change or revoke an existing authorisation.
• ZUS: review PEL authorisations; PEL-O is the revocation form.
• KSeF: review granted and indirect permissions and their removal under the Ministry of Finance guidance.
• Other systems: check the organisation’s e-Urząd Skarbowy account, accounting software, bank access and shared folders.

First agree who handles outstanding submissions and corrections. Then verify the incoming team’s access and remove permissions no longer needed by the outgoing team. Revoking one permission does not necessarily remove the others. Our guide to KSeF for a sp. z o.o. explains the wider company context.

What about JPK_KR_PD when software changes?

If the company falls within JPK_KR_PD reporting, plan coverage of the entire reporting year before access to the old system ends. In questions 120 and 140, the Ministry of Finance explains that reporting must reflect the accounting books. Partial files must preserve continuity without gaps or repeated entries.

Agree account identification, the entries required and who prepares and checks the file. Record this even when both firms use software with the same name. An opening balance or invoice import alone does not demonstrate that annual reporting data is complete. Establish separately when the reporting obligation applies to this particular company.

What should you check after the first month?

Ask the incoming accountant for an unresolved-document list, bank reconciliation and submission receipts. Compare the first reports with the handover package. Check that both sides received corrections to earlier periods and that management can still access records after the old engagement ends.

For a handover close to the year end, revisit responsibility for the annual financial statements. Confirmation that a return was accepted does not establish that the tax was paid. Record both events separately in the task list.

If you use Norman, the accountant export guide explains the package, warnings and format limitations. Downloading a ZIP is neither an automatic transfer of the entire accounting system nor a submission to an authority. Agree the required scope with its recipient. You can assess Norman bookkeeping for Polish limited companies against your company’s specific needs.

Compare capabilities before changing software

If you are considering working with AI assistance or hiring an accounting firm, compare the same scope: Norman and inFakt, Norman and iFirma, Norman and wFirma. Check document extraction, conversation with company data, MCP, company ledgers and who approves and submits returns. A software price does not automatically include a personal accountant.

See invoice migration to Norman and deductible business expenses. Importing invoices is not a handover of ledgers and balances.