The deadline for submitting annual financial statements is approaching, and the formal requirements have changed: the new RDF system starting in February 2026, the requirement for electronic signatures on resolutions, and challenges for foreign nationals without a PESEL number. We explain step by step who signs what, with what type of signature, and through which system.
The financial statements consist of exclusively electronically — It is not possible to file it in paper form or in person at the registry court. There are two options available:
The report itself is prepared in logical structure (XML) in a format specified by the Ministry of Finance. This is not a regular PDF file—it is a structured data document generated by financial and accounting software or the Ministry of Finance’s free “e-Financial Reports” application. The completed XML file is then signed by authorized individuals and uploaded to the system.
The new RDF (launched on February 23, 2026) is fully integrated with the Court Registers Portal (PRS). This means a single sign-on and direct access to company registry data within the system. For details, visit the website ekrs.ms.gov.pl.The Accounting Act identifies two categories of persons required to sign the financial statements:
However, a simplification has been in effect since 2022 (Article 52(2b)): in the case of a board with multiple members, a single signature is sufficient one member of the board of directors, provided that the other members submit statements certifying that the report meets the requirements of the Act. The statements (electronic or on paper with a handwritten signature) must be attached to the report.
Each of these individuals signs the report on an individual basis, one of the acceptable types of signature:
| Signatory | Valid signature | Comments |
|---|---|---|
| Board member from PESEL to KRS | QES (qualified electronic signature) / trusted signature / personal signature | Free RDF track |
| Board member without PESEL in KRS (foreign national) | QES (qualified electronic signature) | S24 (140 zł), when no one on the board holds PESEL in KRS |
| Bookkeeper | QES / trusted signature / personal signature | PESEL is required only for trusted and personal signatures |
| Receiver / Liquidator (instead of the board of directors) | As above | In accordance with the position held |
The key principle of the free RDF path: at least one The person authorized to represent the entity must have PESEL disclosed in KRS, and that person initiates the submission of the documents. Other individuals who do not have PESEL or are not listed in KRS sign the QES.Qualified Electronic Signature (QES) in accordance with the eIDAS Regulation (EU) No. 910/2014 has the same legal effect as a handwritten signature (Article 25(2)) and is recognized in all EU countries (Article 25(3)). For a foreign national without a PESEL number, this is the only signature accepted in all eKRS/RDF systems.
If you're wondering about the difference between the various types of signatures, read: Differences Between a Trusted Profile and a Qualified Electronic Signature.
The year 2026 brought two significant changes that many companies are not yet aware of:
February 23, 2026. A new Financial Documents Repository (RDF) has been launched, and as of March 13, 2026. It is fully integrated with the Court Registers Portal (PRS). The previous eKRS platform no longer supports new submissions. The new system has changed the interface, the login process, and the document submission process—if your company was using the old instructions, please update them.
This is the most important practical change: resolutions of the shareholders' meeting or the general meeting (approval of the financial statements, distribution of profits, or coverage of losses) must be signed with an electronic signature. A scan of the paper minutes or resolution alone is no longer sufficient—the new RDF system rejects documents without an electronic signature, even though the regulations (Article 19e of the KRS Act) have not changed.
In practice, the resolution is either drafted electronically from the outset, or a scan of the paper document is signed with an electronic signature by the authorized person submitting the filing (e.g., a member of the management board under PESEL in KRS). For board members who are foreign nationals—and who do not have access to a trusted digital signature—the only realistic option is qualified electronic signature (QES).
The choice of path depends primarily on the composition of the board of directors and whether any of its members have a PESEL number disclosed in KRS:
| Criterion | Free RDF Registration | Paid S24 (140 zł) |
|---|---|---|
| Required condition | At least 1 person from PESEL in KRS | No condition regarding PESEL |
| Fee | None | 140 zł (court fee and notice in MSiG) |
| Typical application | Companies with a Polish management team or a mixed management team | Companies with a management board composed exclusively of foreign nationals without PESEL in KRS |
| Accepted signatures | QES / trusted signature / personal signature | QES / Trusted Signature |
| Speed | An entry in KRS is posted automatically after the report is verified | The application is reviewed by the registry court |
If at least one member of the management board has PESEL in KRS and can log in to RDF, the free option is the natural choice—and usually the faster one. Other individuals, including foreign nationals, sign the documents with a qualified electronic signature (QES).This is one of the most common problems in companies with foreign capital or management. A foreign national without a PESEL number:
At the same time—a foreign national who is a member of the management board, whose PESEL is not disclosed in KRS, cannot file the report on its own through the free RDF system. In that case, the company files it through S24 (a fee-based application, 140 zł) or through an authorized representative—an attorney or legal advisor—who can file the report for free via the RDF system. When another member of the management board from PESEL initiates the filing in the RDF, the foreign national simply signs the documents with their QES.
A qualified electronic signature is issued based on identity verification. Foreign nationals can undergo the remote video verification process IDnow — without an in-person visit. At podpisano.pl, we offer a customized solution: SimplySign QES for Foreign Nationals with IDnow — a mobile qualified digital signature accepted by all systems in Poland and throughout the EU.
You can read more about this process in the article: How can a foreign national obtain a qualified electronic signature online in Poland?
This same group of companies often also has responsibilities related to KSeF — see: Invoicing Integration with KSeF — Qualified Digital Seal and Permissions.
The procedure for filing financial statements is as follows—the order is important:
The specific legal basis for the submission of financial statements is Article 69 of the Accounting Act of September 29, 1994 (consolidated text: Journal of Laws of 2026, item 522) and the provisions of the Commercial Companies Code regarding the approval of financial statements.For those who sign financial statements, the key criteria are convenience, Compatibility with the RDF/eKRS system and — for foreign nationals — the possibility of obtaining it without PESEL.
| Feature | SimplySign (mobile QES) | Certum Mini (card + reader) |
|---|---|---|
| Certificate medium | Cloud (mobile app or API) | Cryptographic card + USB reader |
| Identity Verification for Foreign Nationals | Remotely (IDnow online, video) or in person | In-person visit to a service center or remote (IDnow online, video) — in that case, however, the card must be physically delivered |
| Browser-based access | Yes (SimplySign Web) | Yes (with the driver installed) |
| Acceptance in RDF/eKRS | Yes | Yes |
| Timestamps | Available, 5,000 per month | 5,000/month included (Certum Mini) |
| Ideal for | Foreigners, field staff, rapid deployments | Intensive in-person signers |
Both solutions are available at podpisano.pl — an authorized Certum partner. If you're not sure which option is right for you, read the comparison: SimplySign or Certum Mini — When to Choose the Right Solution.
The filing of financial statements for KRS in 2026 is entirely electronic and—with proper preparation—runs smoothly. The key is choosing the right signature and knowing the filing process that matches the composition of the board of directors.
As authorized partner Certum We help Polish and foreign companies equip their management boards with qualified digital signatures ready for signing and filing financial statements—including through remote IDnow verification for foreign nationals.
Call us at: +48 22 417 05 55 — We can provide advice at our offices in Warsaw, Kraków, Wrocław, and Radom, or online.
Check out the offer:
For more information about the RDF system, visit: ekrs.ms.gov.pl i prs.ms.gov.pl.
Financial statements must be filed exclusively electronically via the Financial Documents Repository (RDF) on the Court Registers Portal or through the S24 system. Prepared in XML format, they must be signed by the person responsible for maintaining the accounting records and by the management board — all members or, starting in 2022, at least one member, provided the others submit declarations — using a qualified electronic signature (QES), a trusted signature, or a personal signature. The free RDF submission process requires that at least one authorized person have a PESEL number disclosed in KRS.
As a general rule, yes—the financial statements must be signed by all members of the management board and the person responsible for maintaining the accounting records. However, starting in 2022, the signature of a single member of the management board will suffice if the others submit statements confirming that the report meets the requirements of the Accounting Act (Article 52(2b)). A refusal to sign or make such a statement must be accompanied by a written justification attached to the report.
A foreign national without PESEL cannot use a trusted profile or a personal signature. The only available option is qualified electronic signature (QES). It can be obtained remotely through the IDnow service (video verification, without a visit to Poland). The report is submitted to KRS via S24 (for a fee of 140 zł), through a representative (attorney or legal advisor), or—if another member of the management board from PESEL initiates the filing with the RDF—the foreign national merely co-signs the documents with their QES.
Financial statements must be prepared within 3 months of the end of the fiscal year, approved by resolution within 6 months, and filed with RDF or S24 within 15 days of approval. For the 2025 fiscal year, which coincides with the calendar year: preparation by March 31, approval by June 30, and submission no later than July 15, 2026.
No. Resolutions approving the financial statements and the distribution of profits or coverage of losses must bear an electronic signature—the new RDF system rejects scans alone. A scan of a paper resolution must be signed with an electronic signature (e.g., the submitter’s QES) before it is sent.
The new Financial Documents Repository (RDF) has been operational since February 23, 2026, and has been fully integrated with the Court Registers Portal (PRS) since March 13, 2026. It has replaced the previous eKRS platform for the submission of financial documents. The new system features a revised interface and login process and integrates company registration data—financial documents are directly linked to the current KRS entry.
