Electronic signature and financial statements - latest regulations and responsibilities

How to sign financial statements? Guide and best solutions with electronic signatures

Signing financial statements electronically is mandatory today to ensure full regulatory compliance. 

Every company and organization with full accounting is required to prepare and submit annual financial statements annually. This is not just a formality, but a key document reflecting the financial situation of the company.

However, as of 2018, the rules for signing it have changed - the report must be in electronic form and bear an electronic signature.

In 2025, the latest legal and technical requirements for e-reports apply: below we explain who must sign the report, what kind of electronic signature must be used to do so, and how to submit the signed report to the relevant authorities (KRS or KAS) to avoid legal and organizational problems.

Who must sign the financial statements?

According to the Accounting Law, the annual financial statements must be signed by two key individuals:

• The head of the entity - that is, the person or persons who manage the entity (e.g., the chairman of the board of directors, all members of the board of directors in a corporation, the partner in charge of the affairs of a partnership, etc.).
• The person responsible for keeping the books of account - usually the chief accountant or other person entrusted with keeping the books.

If an entity is headed by a multi-member body (e.g., a multi-member board of directors), as a rule, all members of the body should sign the report.

As of January 1, 2022, however, an important simplification has been introduced: it is sufficient for at least one member of the body to sign, and the other members of the board to submit separate statements confirming that the report meets the requirements of the law. Such a procedure is fully compliant with the law and allows for smooth fulfillment of the obligation even with large boards or difficulties in collecting all signatures.

If any authorized board member refuses to sign the report (or refuses to make the aforementioned statement), he or she is required to prepare a written justification for the refusal and attach it to the financial statements. In practice, this means that any person who does not initial the report must explain in writing the reasons - this ensures transparency and compliance with Article 52 of the Accounting Law.

Remember: the signing of the financial statements or management report should take place no later than March 31 of the following year for the fiscal year (if the fiscal year coincides with the calendar year). Thereafter, the reports should be approved by the shareholders or the board of directors and shareholders) by the end of June, and after approval, filed with the relevant register no later than July 15.

In what form should the financial statements be signed?

Currently, financial statements are prepared only in electronic form (.xml file) and can no longer be signed by hand on paper. As of October 1, 2018, the legislator requires that such an e-report be signed electronically.

There are three accepted forms of electronic signature to choose from:

• Qualified electronic signature - the most universal and secure, legally recognized throughout the European Union (compliant with eIDAS). It is a paid certified signature issued by authorized certification centers. Its advantage is full legal force equivalent to a handwritten signature and recognition in all EU countries.
• Trusted profile (ePUAP trusted signature) - a free electronic signature available to those who have a PESEL number and a trusted profile on the ePUAP platform (e.g. through e-banking). Financial statements can also be signed with such a signature. Its limitation is that it is useful only in dealing with Polish offices - it has the status of an advanced (not qualified) signature, but for the purposes of filing the report with the KRS or sending it to KAS it is fully sufficient.
• Personal signature (e-Card) - that is, a digital signature embedded in an electronic ID card. If you have a new ID card with an electronic layer (the so-called e-Card) and have activated a personal signature certificate on it, you can use it to sign the report. The personal signature is also recognized by offices (it is empowered by Polish law as equivalent to a handwritten signature when dealing with the administration). You need an NFC reader or an appropriate app to make such a signature on the document.

In practice, the most convenient solution is to use a qualified electronic signature. It gives the greatest legal certainty and universality - it is honored not only in Poland, but in all EU countries. What's more, modern, user-friendly technologies have emerged in recent years, making it easier than ever to use a qualified signature. For example, solutions of mobile signature in the cloud allow documents to be signed from a smartphone, without the need for a card or reader.

W podpisano.pl we offer two qualified signature solutions

• SimplySign - a mobile qualified signature, which does not require a physical card or reader. The entire process is done via an app on your smartphone or tablet - this means you can sign the document from anywhere, anytime. SimplySign provides full mobility while maintaining the legal force of a handwritten signature. In practical terms, your phone becomes a tool for providing a secure e-signature whenever you need it.
• Certum Mini, on the other hand, is a simple and convenient kit for making qualified electronic signatures on a computer. It consists of a USB reader and a cryptographic card with a qualified certificate. This solution is traditional and highly appreciated by companies - it provides a high level of control and security, although it requires the use of a physical device. The Certum Mini works well, for example, when you work mainly stationary at a computer and depend on a tangible signature carrier. Thanks to its small size, the kit is easy to use and carry, which makes it easy to keep working with e-documents.

Both of the above options meet the standards eIDAS, guaranteeing safety and regulatory compliance.

Current KRS and Ministry of Finance (KAS) requirements

Just signing the report is not enough - it still needs to be properly transmitted to the competent authority. In 2025, there are already well-established rules, according to which the routes for submitting the financial statements depend on the type of entity:

• Companies and other entities registered with the National Court Register (subject to entry in the Register of Entrepreneurs) - submit electronic financial statements to the National CourtRegister. This is done exclusively online through the eKRS portal (Court Electronic Records Access Portal). The report file must have an appropriate format (logical structure defined by the Ministry of Finance) - currently it is an XML structure in accordance with published XSD schemes. The electronic report must include all required elements, such as the balance sheet, profit and loss account, additional information (introduction and notes). The eKRS system allows the documents to be submitted free of charge to the Financial Document Repository, where they go into the company's registration file. An electronic signature will also be needed for the submission of the report itself - on the eKRS portal the submission is signed (qualified, trusted or personal signature) by at least one person authorized to represent, whose PESEL is revealed in the register. In practice, therefore, it is enough for one authorized person (e.g., a member of the board of directors) to log in and send a document bearing an e-signature to fulfill the obligation. It should be remembered that the mere signing of documents in e-KRS is not equivalent to their submission, it is still necessary to send them to the repository, which entrepreneurs forget about, leading to deficiencies in the submitted documents.

Deadline: this must be done within 15 days of the approval of the report - for most companies that approve reports by June 30, this means a deadline of July 15 of the following year. Note: if the report is not approved by the end of June, it still has to be submitted to the KRS as unapproved in July, and after its subsequent approval, send the relevant documents (e.g., the resolution on approval and distribution of profit/loss) to the KRS within the next 15-day deadline.

• Entities not registered in the KRS (e.g., sole proprietorships, civil partnerships, ordinary associations not subject to KRS registration and other entities that settle PIT) - do not file a report with the KRS, but are required to submit it to the Head of the National Tax Administration (KAS), i.e., the de facto tax office. This is also done electronically. The Ministry of Finance provides a special e-Financial Reports application (available through the podatki.gov.pl portal), which can be used to create and send the signed report directly to the KAS system. Alternatively, it is permissible to send the JPK_SF file (i.e., the report file in XML format) through the ePUAP trusted profile to the relevant tax office. Regardless of the method, such a document must be signed electronically (either with a qualified signature, trusted profile or e-document - the same forms as described above) by authorized persons.

Deadline: PIT taxpayers have a shorter time to complete the paperwork - financial statements for the previous year must be submitted to KAS by April 30 (the fourth month) of the following year. For example, for the fiscal year ending December 31, 2024, the deadline for sending to KAS is April 30, 2025. Importantly, the regulations do not require that an already approved report be sent to KAS - we simply send an electronically signed report file (although in practice, the MF system requires the date of approval, if any). If a sole proprietor approves the report himself (because he is the sole owner), often the signing and approval occur simultaneously. On the other hand, when the report is subject to audit by a certified public accountant, the approval may come only after the audit, which should also be kept in mind.

In summary, the financial statements of all entities in Poland in 2025 shall be submitted electronically - either to the KRS Repository (if the entity is subject to entry in the KRS Register of Entrepreneurs) or to the KAS financial system (if the entity is not subject to the KRS). In all cases, the correct format of the document is required (the structure of the e-report can be generated, for example, in a financial-accounting program or in an MF application), as well as a valid electronic signature of authorized persons.

Consequences of not signing or failing to do so

Failure to sign a financial report (or to submit it by the required deadline) can result in serious legal and financial consequences. First of all, such a document will not be accepted by the competent authority - the KRS or KAS system will reject a report that has not been accompanied by the required electronic signatures of all obligated persons. Failure to properly submit the report is a violation of the law, for which there are penalties.

Disregarding the obligation to sign and submit financial statements carries risks far more serious than just a minor inconvenience. That's why it's so important to ensure that deadlines and formal requirements are met.

Electronic signature means convenience and full regulatory compliance

With these consequences in mind, it is worth betting on a convenient, fast and 100% legal solution- a qualified electronic signature. It will allow you to sign financial statements (and other company documents) literally in a matter of moments - without printing, hand-signing each printout and scanning it.

A qualified electronic signature is equivalent to a handwritten signature and meets all the requirements of the KRS and the Ministry of Finance. If you are still in doubt which signature to choose - please visit podpisano.pl - we will help you choose such a qualified signature that best suits the specifics of your work. SimplySign - if you are often on the go or work remotely - a mobile signature on a smartphone will be ideal. Certum Mini - if you prefer traditional hardware solutions, a set with a reader will work just as well.

In summary, to properly sign the financial statements and sleep soundly:

1. Prepare the report in electronic form (e.g., generate an XML file from your financial system according to the MF structure).
2. Take care of the electronic signatures of all the required persons - the head of the entity (or board member + statements of the others) and the person who keeps the books. Choose the form of signature: preferably qualified, or alternatively a trusted profile or e-card.
3. Submit the signed e-report to the appropriate system: eKRS (for companies and entities on the register) or e-Reports/KAS (for others). Meet the statutory deadlines - usually 15 days after approval for KRS or by April 30 for KAS.
4. Archive proof of filing (official receipt or confirmation from the system). In the case of the KRS, this is not necessary - the filed report is almost immediately visible on the copy of the KRS

Thanks to the use of modern electronic signatures, the whole process is fast and efficient, and most importantly - compliant with current regulations.

In 2025, electronic reporting is a standard that helps businesses save time and minimize the risk of errors. Take advantage of the e-signature solutions available, and signing financial statements will become a routine activity that requires no unnecessary effort. Whether you choose SimplySign or Certum Mini, you'll gain confidence that your document meets all formal requirements - and without leaving your office.

Take care of the correct electronic signature now, and your company's annual financial report will be filed on time, hassle-free and stress-free.

SimplySign and Certum Mini qualified signatures

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