Signing and submission of financial statements to the Polish National Court Register in XML format 

Sprawozdania finansowe w XML

Every entity that keeps accounting ledgers is obligated to draw up a financial statement in an electronic form (referred to later on in this article as “XML”) and sign it with a qualified electronic signature or trusted signature of the person entrusted with keeping the accounting ledgers and the head of the entity – the signature should be affixed by the whole Management Board or, pursuant to the changes introduced on 1 January 2022 in the Polish Accounting Act (“AA”) (Art. 52 section 2b) – one member of multi-member board while the other members of the management board are obligated to file a proper declaration in the system.   

There has been no one specific template of the above-mentioned declaration. However, its contents must include an expression that the financial statement meets the requirements stipulated in the AA. It is necessary to indicate the financial statement that the expression refers to by providing the date and time of signing of that statement by the person entrusted in management of the accounting ledgers (Art. 52 section 2c). The declaration can be drawn up in two forms: printed (with a signature affixed by hand) or electronic (signed electronically with a qualified electronic signature, a trusted signature or personal signature).  

If the declarations are drawn up in a printed form, it is necessary to prepare their electronic form (by scanning them) so that they can be attached to the e-financial statement – it is the duty of the member of the management board who signed the financial statement (Art. 52 section 2e). What is more, there is no obligation of authenticating the copy with an electronic signature at this stage. The solutions apply in a similar way to the refusal to file a declaration.  

The e-statement is usually signed first by the person entrusted with the management of accounting ledgers (preferably on the date of preparation of the XML file, as confirmation of the existence of specific material and financial status as of particular balance sheet date; however, the Act does not clearly indicate whether the first signature must be affixed on the same day). Next, the statement is signed by members of the management board – the above-mentioned order applies in a situation when none of the above-mentioned persons uses a trusted signature of the ePUAP platform (the Polish Public Administration Services Electronic Platform) (it is recommended that signatures in form of ePUAP signatures should be affixed first – which will be described later on).  

Signatures of individual members of a multi-member management board do not need to be affixed on the same day. However, in order to make the financial statement complete and in line with the AA, it must be signed by all the members not later than within three months from the balance sheet date.   


Author: Izabella Kuźma, Senior Specialist of the Reporting Department  at the MDDP Outsourcing office in Warsaw 



Polish Accounting Act of 29 September 1994. 

ePUAP trusted signature. 

Repository of Financial Documents. 

Frequently asked questions within the scope of electronic financial statements.   


Read more: 

The obligation of audit of a financial statement carried out by a statutory auditor 

Audit of a financial statement for 2021 – choosing the auditor