What Can an Accountant Do in Poland? Scope of Services, Limits, and Liability
Symmetris.pl | We do accounting and bookkeeping in Warsaw and throughout Poland
Many business owners in Poland, especially those who have moved here from abroad, assume that their accountant will "handle everything".
Many business owners in Poland, especially those who have moved here from abroad, assume that their accountant will "handle everything". That means invoices, taxes, social security, and even disputes with the tax office.
In some countries accountants routinely give tax advice and represent clients before the tax authority, so the expectation is understandable. Polish law, however, draws clear lines between what an accountant can do and what is reserved for a licensed tax advisor, a statutory auditor, or a lawyer.
This guide explains where those lines are and who is liable for accounting mistakes. It also shows how to check whether an accounting office in Poland operates legally.
In some countries accountants routinely give tax advice and represent clients before the tax authority, so the expectation is understandable. Polish law, however, draws clear lines between what an accountant can do and what is reserved for a licensed tax advisor, a statutory auditor, or a lawyer.
This guide explains where those lines are and who is liable for accounting mistakes. It also shows how to check whether an accounting office in Poland operates legally.
Who Is an Accountant in Poland? The Legal Framework
Since 2014 the accounting profession in Poland has been deregulated. Running an accounting office (biuro rachunkowe) no longer requires a certificate from the Minister of Finance. That does not mean there are no rules. Under Article 76a of the Polish Accounting Act (ustawa o rachunkowości), bookkeeping services must meet several requirements.
First, the people keeping the books must have full legal capacity. They must also have no final conviction for offences such as those against the credibility of documents, business transactions, property, or money circulation, or for fiscal offences.
Second, the accounting office must hold mandatory professional liability insurance (OC). The policy protects the client if a mistake by the office causes financial loss.
Third, accounting offices are "obliged institutions" under the Polish Anti-Money Laundering Act (AML). They must identify their clients and beneficial owners and monitor transactions.
First, the people keeping the books must have full legal capacity. They must also have no final conviction for offences such as those against the credibility of documents, business transactions, property, or money circulation, or for fiscal offences.
Second, the accounting office must hold mandatory professional liability insurance (OC). The policy protects the client if a mistake by the office causes financial loss.
Third, accounting offices are "obliged institutions" under the Polish Anti-Money Laundering Act (AML). They must identify their clients and beneficial owners and monitor transactions.
What Can an Accountant Do? Scope of Services
The Polish Act on Tax Advisory Services (ustawa o doradztwie podatkowym) allows businesses that provide bookkeeping services to do two things. They can keep books and tax records on behalf of clients and prepare their tax returns. They can also assist clients in these areas. In practice, this covers a wide range of services.
Bookkeeping and Tax Records
An accountant keeps the revenue records for businesses on the lump-sum tax (ryczałt). For businesses taxed on the progressive scale or the flat rate, they keep the tax revenue and expense ledger (KPiR). For limited liability companies (Sp. z o.o.), they keep full accounting books. The work also covers VAT registers, fixed asset records, settlements with contractors, and checking that documentation is complete.
Tax Returns and Social Security (ZUS)
An accounting office prepares and files VAT returns and JPK_VAT files, as well as PIT and CIT returns. It also prepares the annual PIT-11 and PIT-4R forms for employers and the monthly ZUS DRA social security declarations. This includes reporting crypto-asset income on the PIT-38 return. To sign and submit documents on the client's behalf, the accountant needs a power of attorney. For the tax office (Urząd Skarbowy), this is mainly the UPL-1 form. For the Social Insurance Institution (ZUS), it is the ZUS-PEL form.
HR and Payroll
An accountant can prepare payroll and handle settlements under employment contracts and civil law contracts (umowa zlecenia, umowa o dzieło). They register employees with ZUS, calculate contributions and tax advances, and prepare the annual employee tax forms. If the contract provides for it, they can also keep employee records.
KSeF: Poland's National e-Invoicing System
With the introduction of mandatory e-invoicing through KSeF (Krajowy System e-Faktur), the accountant's role is growing. Once the client grants the right permissions in KSeF, the accountant can download the client's purchase invoices. With the client's consent, they can also issue sales invoices on the client's behalf.
Communication with the Tax Office and ZUSActing under a power of attorney, an accountant files tax returns and corrections. They also prepare replies to official requests about the settlements they handle and submit the documents the authorities ask for. For a business owner, this means most day-to-day correspondence with the tax office and ZUS can be handled by the accounting office.
Annual Financial Statements
For limited liability companies, the accountant prepares the annual financial statements. Under Article 52 of the Accounting Act, these are signed by the person responsible for keeping the books and by the head of the entity (for example, the members of the management board). The accountant also prepares the documents needed to file the statements with the National Court Register (KRS) and the tax office.
Ongoing Support with Your Settlements
A good accountant does more than record documents. They keep track of deadlines and explain how a given transaction will affect your settlements. They also flag risks and let you know when regulations change. They can prepare a simulation of your tax and ZUS costs under different taxation forms. The final decision, however, always rests with the business owner.
Bookkeeping and Tax Records
An accountant keeps the revenue records for businesses on the lump-sum tax (ryczałt). For businesses taxed on the progressive scale or the flat rate, they keep the tax revenue and expense ledger (KPiR). For limited liability companies (Sp. z o.o.), they keep full accounting books. The work also covers VAT registers, fixed asset records, settlements with contractors, and checking that documentation is complete.
Tax Returns and Social Security (ZUS)
An accounting office prepares and files VAT returns and JPK_VAT files, as well as PIT and CIT returns. It also prepares the annual PIT-11 and PIT-4R forms for employers and the monthly ZUS DRA social security declarations. This includes reporting crypto-asset income on the PIT-38 return. To sign and submit documents on the client's behalf, the accountant needs a power of attorney. For the tax office (Urząd Skarbowy), this is mainly the UPL-1 form. For the Social Insurance Institution (ZUS), it is the ZUS-PEL form.
HR and Payroll
An accountant can prepare payroll and handle settlements under employment contracts and civil law contracts (umowa zlecenia, umowa o dzieło). They register employees with ZUS, calculate contributions and tax advances, and prepare the annual employee tax forms. If the contract provides for it, they can also keep employee records.
KSeF: Poland's National e-Invoicing System
With the introduction of mandatory e-invoicing through KSeF (Krajowy System e-Faktur), the accountant's role is growing. Once the client grants the right permissions in KSeF, the accountant can download the client's purchase invoices. With the client's consent, they can also issue sales invoices on the client's behalf.
Communication with the Tax Office and ZUSActing under a power of attorney, an accountant files tax returns and corrections. They also prepare replies to official requests about the settlements they handle and submit the documents the authorities ask for. For a business owner, this means most day-to-day correspondence with the tax office and ZUS can be handled by the accounting office.
Annual Financial Statements
For limited liability companies, the accountant prepares the annual financial statements. Under Article 52 of the Accounting Act, these are signed by the person responsible for keeping the books and by the head of the entity (for example, the members of the management board). The accountant also prepares the documents needed to file the statements with the National Court Register (KRS) and the tax office.
Ongoing Support with Your Settlements
A good accountant does more than record documents. They keep track of deadlines and explain how a given transaction will affect your settlements. They also flag risks and let you know when regulations change. They can prepare a simulation of your tax and ZUS costs under different taxation forms. The final decision, however, always rests with the business owner.
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What an Accountant in Poland Cannot Do
The limits of an accountant's role come from the Act on Tax Advisory Services, the Accounting Act, the Fiscal Penal Code, and AML regulations.
Give Tax Advice or Formal Tax Opinions
Under Polish law, providing tax advice, opinions, and explanations as a professional service is reserved for licensed tax advisors (doradca podatkowy), attorneys (adwokat), legal counsels (radca prawny), and statutory auditors (biegły rewident). An accountant will explain how an invoice will be recorded and how it affects your tax return, because that is part of assisting with the settlements they handle. A written tax opinion, a tax optimisation strategy, an analysis of a restructuring, or an application for an individual tax ruling (interpretacja indywidualna) are tasks for a tax advisor.
Professionally Represent You in Tax Proceedings or in Court
Professional representation in tax proceedings or during a customs and tax audit is a tax advisory service. Before the Voivodeship Administrative Courts (WSA) and the Supreme Administrative Court (NSA), a representative in tax matters can be a tax advisor, an attorney, or a legal counsel, but not an accountant. An accountant can, however, prepare documents and explanations about the books they keep.
Audit Financial StatementsOnly a statutory auditor can audit financial statements. The audit requirement applies to companies that exceed the thresholds set out in Article 64 of the Accounting Act. An accountant prepares the financial statements but does not audit them.
Make Decisions or Sign Documents on Your Behalf Without Authorisation
Without a power of attorney, an accountant cannot sign a tax return or file an application on your behalf. They do not sign contracts, approve the financial statements (in a company, that is done by the shareholders' meeting), or decide on company spending. They can only order payments from your bank account if your contract expressly provides for this and the bank has granted the appropriate authorisation.
Record False or Backdated Documents
An accountant cannot record fictitious invoices or backdate documents. They also cannot help conceal revenue or inflate costs. Keeping unreliable books and using false invoices can lead to liability under the Fiscal Penal Code and, in more serious cases, under the Criminal Code. An accountant has the right, and in fact the duty, to refuse to record a document that raises reasonable doubts.
Ignore AML Obligations
An accounting office cannot take on a client without identifying and verifying them. When an accountant asks for your ID or for details of your company's beneficial owner, this is not excessive caution but a legal requirement. The office must report suspicious transactions to the General Inspector of Financial Information (GIIF) and is not allowed to warn the client about the report.
Handle Matters Outside Accounting
Residence permits, disputes with business partners, employment litigation, and drafting commercial contracts are outside the scope of accounting services. An accountant can prepare the financial documents you may need, for example for a residence permit (karta pobytu) application. These can include a summary of your income or confirmation that your tax and ZUS settlements are up to date. The matter itself, however, should be handled by a lawyer or another qualified specialist.
Give Tax Advice or Formal Tax Opinions
Under Polish law, providing tax advice, opinions, and explanations as a professional service is reserved for licensed tax advisors (doradca podatkowy), attorneys (adwokat), legal counsels (radca prawny), and statutory auditors (biegły rewident). An accountant will explain how an invoice will be recorded and how it affects your tax return, because that is part of assisting with the settlements they handle. A written tax opinion, a tax optimisation strategy, an analysis of a restructuring, or an application for an individual tax ruling (interpretacja indywidualna) are tasks for a tax advisor.
Professionally Represent You in Tax Proceedings or in Court
Professional representation in tax proceedings or during a customs and tax audit is a tax advisory service. Before the Voivodeship Administrative Courts (WSA) and the Supreme Administrative Court (NSA), a representative in tax matters can be a tax advisor, an attorney, or a legal counsel, but not an accountant. An accountant can, however, prepare documents and explanations about the books they keep.
Audit Financial StatementsOnly a statutory auditor can audit financial statements. The audit requirement applies to companies that exceed the thresholds set out in Article 64 of the Accounting Act. An accountant prepares the financial statements but does not audit them.
Make Decisions or Sign Documents on Your Behalf Without Authorisation
Without a power of attorney, an accountant cannot sign a tax return or file an application on your behalf. They do not sign contracts, approve the financial statements (in a company, that is done by the shareholders' meeting), or decide on company spending. They can only order payments from your bank account if your contract expressly provides for this and the bank has granted the appropriate authorisation.
Record False or Backdated Documents
An accountant cannot record fictitious invoices or backdate documents. They also cannot help conceal revenue or inflate costs. Keeping unreliable books and using false invoices can lead to liability under the Fiscal Penal Code and, in more serious cases, under the Criminal Code. An accountant has the right, and in fact the duty, to refuse to record a document that raises reasonable doubts.
Ignore AML Obligations
An accounting office cannot take on a client without identifying and verifying them. When an accountant asks for your ID or for details of your company's beneficial owner, this is not excessive caution but a legal requirement. The office must report suspicious transactions to the General Inspector of Financial Information (GIIF) and is not allowed to warn the client about the report.
Handle Matters Outside Accounting
Residence permits, disputes with business partners, employment litigation, and drafting commercial contracts are outside the scope of accounting services. An accountant can prepare the financial documents you may need, for example for a residence permit (karta pobytu) application. These can include a summary of your income or confirmation that your tax and ZUS settlements are up to date. The matter itself, however, should be handled by a lawyer or another qualified specialist.
Accountant vs Tax Advisor vs Statutory Auditor vs Lawyer
Who Is Liable for Accounting Mistakes?
This is one of the most common questions business owners ask, and the answer has several layers.
Towards the tax authorities, the business owner is liable.
In a limited liability company, Article 4a of the Accounting Act makes the head of the entity, meaning the management board, responsible for the company's accounting. This applies even when the books are kept by an external accounting office. The office can formally accept responsibility for keeping the books, but the management board remains responsible for supervision. In a sole proprietorship (JDG), the owner is the taxpayer and will pay any tax arrears with interest.
Towards the client, the accounting office is liable. If a loss results from the office's mistake, such as a late tax return or an incorrectly recorded document, the client can claim compensation under the service agreement. This is exactly what the mandatory liability insurance is for.
Fiscal criminal liability. Under Article 9 § 3 of the Fiscal Penal Code, a person who handles a taxpayer's financial affairs under a contract can also be liable for fiscal offences. If a mistake results from the accountant's actions, fiscal criminal liability may rest with them.
That is why a written agreement with your accounting office is so important. It should clearly define the scope of services, the deadlines for delivering documents, and the rules of liability.
Towards the tax authorities, the business owner is liable.
In a limited liability company, Article 4a of the Accounting Act makes the head of the entity, meaning the management board, responsible for the company's accounting. This applies even when the books are kept by an external accounting office. The office can formally accept responsibility for keeping the books, but the management board remains responsible for supervision. In a sole proprietorship (JDG), the owner is the taxpayer and will pay any tax arrears with interest.
Towards the client, the accounting office is liable. If a loss results from the office's mistake, such as a late tax return or an incorrectly recorded document, the client can claim compensation under the service agreement. This is exactly what the mandatory liability insurance is for.
Fiscal criminal liability. Under Article 9 § 3 of the Fiscal Penal Code, a person who handles a taxpayer's financial affairs under a contract can also be liable for fiscal offences. If a mistake results from the accountant's actions, fiscal criminal liability may rest with them.
That is why a written agreement with your accounting office is so important. It should clearly define the scope of services, the deadlines for delivering documents, and the rules of liability.
Your Obligations Towards Your Accountant
Cooperation works both ways. Even the best accountant cannot correctly settle documents they never received. As a business owner, you should:
- deliver documents by the deadline set in your agreement, usually within a few days after the end of the month;
- inform your accountant about changes such as a new type of business activity, hiring an employee, buying a car, foreign transactions, or crypto-asset operations;
- grant the necessary powers of attorney and permissions (UPL-1, ZUS-PEL, KSeF access);
- pay taxes and ZUS contributions on time, based on the amounts your accountant provides;
- keep your records for the period required by law, generally 5 years from the end of the year in which the tax payment deadline passed.
How to Check Whether an Accounting Office in Poland Operates Legally: A Checklist
Before signing an agreement, ask the accounting office these questions:
- Does it have valid professional liability insurance? A reliable office will show you proof without hesitation.
- Does it offer a written agreement with a clear scope of services and liability rules?
- Does it follow AML and KYC procedures? A request for your ID documents is a good sign.
- How does it protect client data under the GDPR, and does it sign a data processing agreement?
- Does it clearly communicate what falls outside its scope and tell you when you need a tax advisor or a lawyer?
How Symmetris Works
At Symmetris, we provide accounting services for sole proprietorships (JDG) and limited liability companies (Sp. z o.o.) in Warsaw and online throughout Poland. We handle VAT, EU VAT and VAT OSS, HR and payroll, KSeF, and crypto-asset reporting. We work with clients in English, Polish, Russian, and Ukrainian.
We work transparently: we tell you clearly what is part of our job and when your matter requires a tax advisor or a lawyer. We protect our clients' data and follow AML and KYC procedures, because behind every figure stands the reputation of a real business.
Want to see how we can take accounting off your plate? Book a free consultation
We work transparently: we tell you clearly what is part of our job and when your matter requires a tax advisor or a lawyer. We protect our clients' data and follow AML and KYC procedures, because behind every figure stands the reputation of a real business.
Want to see how we can take accounting off your plate? Book a free consultation
Frequently Asked Questions
Yes, but only with a power of attorney: the UPL-1 form for tax returns and the ZUS-PEL form for ZUS documents.
Towards the tax office, the taxpayer is liable, and in a company also the management board. If a mistake was the accounting office's fault, you can claim compensation under your agreement and the office's liability insurance. The accountant may also face fiscal criminal liability.
An accountant can prepare a simulation of your costs under the lump-sum tax, the progressive scale, and the flat tax. The decision is yours. In complex situations, such as restructuring or international transactions, it is worth consulting a tax advisor.
No. Since 2014 a certificate from the Minister of Finance is no longer required. However, accountants must have a clean criminal record, hold mandatory liability insurance, and comply with AML regulations.
An accountant can prepare documents and explanations about the books they keep. Professional representation in tax proceedings and before administrative courts is a task for a tax advisor, an attorney, or a legal counsel.
Yes. If a document raises reasonable doubts about its reliability, the accountant should clarify it with you and, if necessary, refuse to record it.
Accounting offices are obliged institutions under the Polish AML Act. They must identify their clients and, for companies, the beneficial owner.
This article is for information purposes only and does not constitute tax or legal advice.
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This article is for informational purposes only and does not constitute tax or legal advice. Tax regulations change regularly — we recommend consulting a qualified professional before making any decisions.
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