The tax administration is increasingly relying on data from the Standard Audit File for Tax (JPK) and the National e-Invoicing System (KSeF) rather than traditional audits. A report by MDDP and the Lewiatan Confederation indicates that in 2025, tax authorities conducted approximately 2.3 million verification activities, equivalent to about 19 new procedures initiated per minute. These activities led to the identification of nearly PLN 11 billion in tax arrears, representing an increase of over 25% compared to the previous year.
– We are observing a shift in the nature of the relationship between the tax authorities and taxpayers. The method of verifying taxpayer returns has changed. While in previous years this verification occurred to a significantly greater extent through standard customs and tax controls, recently it has taken a simplified, more accommodating form of a verification activity – states Tomasz Michalik, partner and tax advisor at MDDP Law Firm, to Newseria.
Data from the second edition of the report “Entrepreneurs Under the Tax Authority’s Magnifying Glass,” prepared by MDDP and the Lewiatan Confederation, show that between 2021 and 2025, over 12.4 million so-called verification activities were carried out. Of these, 10.6 million pertained to VAT, PIT, CIT, and excise tax. These activities helped uncover PLN 38.8 billion in tax arrears, with over PLN 37 billion related to VAT, PIT, CIT, and excise tax. According to the report’s authors, verification activities yield greater benefits for the budget than tax and customs-tax controls combined.
Since 2022, the number of annual verification activities has steadily increased. In the past year alone, nearly 2.3 million were conducted – a 10% rise from the previous year and a 23% increase compared to 2022. The exception was 2021, when the number of verification activities exceeded 2.4 million.
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– A verification activity is a procedure where tax authorities examine certain taxpayer returns, possibly asking for clarifying questions to confirm the correctness of the return. Generally, they either issue recommendations, such as a report from the verification activities, based on which the company corrects its declaration, or if they find no irregularities, these activities conclude without further action – explains Przemysław Pruszyński, Director of the Tax Department at the Lewiatan Confederation.
Verification activities are simpler and less formalized than traditional audits, allowing for rapid and large-scale review of selected areas of tax returns. They are also not burdened by the procedural limitations imposed by regulations. The increasing access of authorities to data and analytical tools, which enable desk-based verification of returns, often without prior contact with the taxpayer, is also significant.
– The tax administration possesses more information about taxpayers. Companies submit an increasing amount of data, starting with JPK_VAT files to this year’s novelty, the National e-Invoicing System. The administration has visibility into virtually complete taxpayer settlements, thus eliminating the need for on-site audits. Instead, they remotely verify the correctness of company filings – explains Przemysław Pruszyński.
In 2021, the average value of findings per verification activity was PLN 1,705, whereas in 2025, it rose to PLN 4,681, with a similar number of procedures. This may indicate that tax authorities are becoming more effective in selecting entities for verification and are better utilizing available analytical tools.
– The tax authorities are leveraging the information they have been able to gather through JPK and other methods to a much greater extent than before. It is evident that they are capable of efficiently analyzing the sources of this data. Consequently, verification activities are targeted at specific taxpayers, specific actions, and areas where the tax authority is already well-prepared. This makes these activities effective, efficient, and successful – emphasizes the tax advisor from MDDP Law Firm.
More formalized tools like JPK, KSeF, DAC7, and STIR mean that businesses now operate under a state of continuous 24/7 monitoring. Tax authorities often possess most of the information they need when contacting an entity.
– This could lead to almost permanent taxpayer surveillance, as nearly all information will be available to tax authorities in real-time or near real-time. We are on the verge of a major transformation concerning control capabilities and likely the methodology of conducting controls – asserts Tomasz Michalik.
A survey conducted for the report reveals that 91.3% of respondents have encountered verification activities within the last five years. Entrepreneurs generally view this form of interaction with the tax authorities positively. 47.1% of respondents rated it as good or very good, while 15.4% rated it as poor or very poor.
– A verification activity is easy, simple, and pleasant in the interactions between both parties. However, it does not guarantee the same rights to taxpayers, and thus can unfortunately be misused – assesses the tax advisor from MDDP Law Firm.
Entrepreneurs surveyed for the report expect greater predictability in this procedure. 89.5% of respondents supported formal notification of their conclusion, 87.5% wished to receive a document with the results and findings, and 85.5% indicated the need to define the maximum duration of such activities. The entrepreneurs’ responses, as highlighted by the report’s authors, should be interpreted as a desire for a basic informational standard, not a demand for excessive formalization. Without information about the conclusion and outcome of verification activities, they remain an opaque procedure for the taxpayer. The duration and recurrence of these activities are also crucial. The survey results show that entrepreneurs do not question the procedure’s flexibility or the ongoing email and phone contact with officials, but these cannot continue indefinitely.
Simultaneously, it is important for taxpayers to maintain appropriate boundaries for this procedure. They do not want verification activities to resemble full tax audits. The report indicates that 61.5% of respondents oppose the expansion of tax authorities’ evidentiary powers, and 72.1% do not support the possibility of interrogating witnesses and parties or conducting inspections within the framework of this procedure.
– Generally, the tax system is becoming increasingly complex, with more issues, interpretations, and disputes between taxpayers and the tax administration, leading to varied resolutions. Consequently, the operations of businesses are becoming more demanding – assesses an expert from the Lewiatan Confederation.
The primary expectation of entrepreneurs is a reduction in the number of changes to tax law. If changes are introduced, businesses expect a longer vacatio legis to allow them to prepare for new obligations.
In the International Tax Competitiveness Index 2025, compiled by the American think tank Tax Foundation, Poland ranked in the lower portion of the list. The country secured 35th place among 38 OECD countries, down from 31st the previous year. This indicates that Poland’s tax system competitiveness is weaker compared to most developed economies.
– Continuous changes are the most challenging for entrepreneurs because they necessitate ongoing implementation, preparation, incurring costs, and fulfilling tax obligations. Then, it turns out that after the entrepreneur has done all this and was about to pay under the existing rules, a new change appears the following year, and then another – states Przemysław Pruszyński.
Experts discussed the relationships between entrepreneurs and the tax authorities during the Tax Council Congress of the Lewiatan Confederation, held on June 16 in Warsaw.