Statutory auditor and a sole proprietorship (JDG) in 2026 — full accounting and the statement audit — in Poland
When a sole proprietorship (JDG) switches to full accounting books and when the financial statement requires an audit: the EUR 2.5 million threshold and the 2-of-3 audit thresholds test.
A sole proprietorship (JDG) does not need a statutory auditor merely because it runs a business. First you have to determine whether it is required to keep full accounting books, and then — separately — whether its annual financial statement meets the criteria for a mandatory audit.
Polish sole trader: full books and audit are separate tests
Two separate thresholds
- The full-accounting threshold decides whether an entrepreneur who is a natural person may stay on the KPiR or the revenue register.
- The audit thresholds decide whether the financial statement of an entity keeping full accounting books must be audited by an audit firm.
Exceeding the first threshold does not automatically mean a mandatory audit.
The full-accounting threshold
Since 2025 the statutory limit has been the equivalent of EUR 2.5 million in net revenue from the sale of goods and products for the previous financial year.
For conversion, the average NBP exchange rate from the first business day of October of the year preceding the financial year in question is used.
You should not apply the old EUR 2 million threshold or a random year-end exchange rate.
Once the limit is exceeded, the sole proprietorship (JDG) keeps full accounting books from the following year. An entrepreneur below the limit may choose full accounting voluntarily, after meeting the notification requirements.
KPiR and the lump sum
The Accounting Act threshold is not the only limit that affects the form of records. The lump sum (ryczałt) has its own revenue limit and conditions, and taxpayers carrying on certain types of activity may be excluded regardless of the full-accounting threshold.
You should not write that every sole proprietorship (JDG), once it exceeds EUR 2.5 million, automatically switches from the lump sum straight to the KPiR or vice versa — the consequence is the obligation to keep accounting books, while the PIT form requires a separate analysis.
When a statement is subject to audit
For the remaining entities that are not covered by an audit on account of their status alone, the obligation arises when, in the previous financial year, they met at least two of the three conditions:
- average annual employment of at least 50 full-time equivalents,
- total balance-sheet assets at year end of at least the equivalent of EUR 3.125 million,
- net revenue from the sale of goods and products and from financial operations of at least the equivalent of EUR 6.25 million.
The thresholds were raised for financial years beginning after 31 December 2024. The old figures of EUR 2.5 million in assets and EUR 5 million in revenue are not the correct ones for auditing the statement for 2026.
Can the 2-of-3 test apply to a sole proprietorship (JDG)
Yes. If a sole proprietorship (JDG) keeps accounting books and prepares a statement on the basis of the Accounting Act, it may fall into the "remaining entities" category subject to the 2-of-3 test.
It is incorrect to claim that the test applies only to companies and never to a natural person running a business.
How to convert the audit thresholds
Amounts in euros are converted into zloty at the average NBP exchange rate as of the balance-sheet date for assets and revenue, in line with the rule of the Accounting Act.
You should not use the same exchange rate as for the full-accounting threshold. These are two different mechanisms and conversion dates.
An example without false precision
A sole proprietorship (JDG) keeping accounting books has:
- employment below 50 full-time equivalents,
- assets above the threshold,
- revenue above the threshold.
It meets two conditions, so its statement may be subject to a mandatory audit despite employment below 50 people.
If it exceeds only revenue, but neither assets nor employment, the 2-of-3 test is not met.
Who chooses the auditor
The audit firm is chosen by the body that approves the statement or another body indicated in the contract, the articles of association or the regulations. The head of the entity should not choose the auditor themselves if the law assigns the choice to a different body.
In a sole proprietorship (JDG) the procedure has to be matched to the structure of the entity and the provisions of the Act.
The term of the contract
The contract is concluded for a period that allows the audit firm to take part in the stocktaking of material assets and to carry out the audit before the statement is approved.
The first contract for a mandatory audit should cover at least two years if the Act on Statutory Auditors and the given situation require it. It is not worth waiting until the day the statement is drawn up.
Voluntary audit
A sole proprietorship (JDG) may commission an audit voluntarily, for example before:
- selling the business,
- an investor coming in,
- major financing,
- a transformation,
- tidying up the books after rapid growth.
A voluntary audit does not change the statutory thresholds, but it can increase the credibility of the data.
The most common mistakes
- Applying an EUR 2 million full-accounting threshold.
- Treating exceeding EUR 2.5 million as an automatic audit.
- Using the old EUR 2.5/5 million thresholds for the audit test.
- Claiming that the 2-of-3 test never applies to a sole proprietorship (JDG).
- Using a single exchange rate for both types of thresholds.
- Comparing gross revenue against the wrong statutory definition.
- Choosing the audit firm too late.
- Confusing the statutory auditor with the accountant who keeps the books.
Sources
Need to prepare your books for an audit?
Oxyok tidies up the records of a sole proprietorship (JDG), reconciles the documents and prepares the data for the accountant or auditor. The scope and price of full accounting are set individually.
This material is general in nature. The obligation depends on the definition of revenue, exchange rates, the entity's status and the previous year's data.