Document transfer protocol when changing an accountant in 2026 — in Poland

The document transfer protocol is a written summary of what one office transfers to the other at the end of cooperation. There is no single official form or imposed template. In the event of a dispute, however, it is simple proof of exactly what was communicated, to whom and when.

This article expands the "handover protocol" section of the guide how to change your accountant in 2026 with a specific checklist. Related topics: UPL-1 - power of attorney for e-declaration and PEL - power of attorney for ZUS.

What a protocol is - and what it isn't

The handover protocol may be a bilateral document drawn up between the current office and the entrepreneur or - depending on the agreed process - with the involvement of the new office. There is no statutory set of pages or mandatory signatures. The document serves three purposes:

• lists specific data sets, periods and formats,
• indicates the cut-off date of the takeover,
• confirms that the parties know who is responsible for what period.

What the protocol isn't:

• an official mandatory form (it is not included in any act),
• a substitute for reporting to CEIDG, ZUS or tax office,
• automatic protection against liability for the predecessor's mistakes,
• basis for issuing documents in a dispute - the contract and storage regulations apply there.

The protocol is an organizational tool, not a law. It's worth having, but its strength depends on the specificity of the entries.

Protocol elements - full checklist

The list below is the minimum that should be included in the handover protocol. Each point requires specific data: period, number of items, file format and shipping status.

Page data

• full details of the current office and entrepreneur,
• full details of the new office,
• date and place of preparation of the protocol,
• data and signatures of the parties involved in the transfer,
• possibly attachments: lists, exports, confirmations.

Cut-off date

• a specific day (preferably the last day of the month) until which the current office is responsible for registration,
• the day from which the new records begin,
• indication of who records documents dated in the border period.

The date must be precise. “End of the third quarter” or “end of cooperation” is not enough.

Accounting records

• KPiR or revenue records broken down by months,
• accounting books (balance sheet, profit and loss account, turnover and balances) - with full books,
• VAT sales and purchase registers,
• records of fixed assets and WNiP,
• list of equipment (if kept),
• contractor and settlement files,
• inventories and inventory sheets.

More about the register of fixed assets in a separate article: record of fixed assets in JDG and depreciation of fixed assets in JDG.

Declarations and JPK

• JPK_V7 for each month; in the case of quarterly settlements, also the correct declaration parts of JPK_V7K for the month ending the quarter,
• VAT-EU for each month in which the obligation to submit information arose,
• payer's declarations and information (PIT-8AR, PIT-4R), if the company employs employees,
• annual returns PIT-36, PIT-36L or PIT-28,
• corrections of submitted declarations,
• details of the submitted JPK_V7 are described in the article JPK_V7 in JDG.

Do not ask for "VAT-7" or "PIT-5". VAT-7 replaced JPK_V7, and PIT-5 is not a monthly JDG advance declaration. The PIT advance is calculated and paid without submitting a declaration.

UPO and confirmations

• UPO for each e-declaration and JPK sent,
• confirmation of sending ZUS documents, including DRA, RCA and RSA,
• official confirmation of submission or delivery (UPP/UPD), depending on the channel used.

PDF declaration is not the same as UPO. Without the UPO, you have no proof that the declaration actually arrived and was accepted.

Fixed assets

• files with the date of receipt, initial value, rate and depreciation method,
• previous depreciation write-offs,
• list of unamortized assets,
• purchase and possible liquidation documents.

Settlements and balances

• open positions with counterparties,
• balances as of the cut-off date,
• unsettled advances and payments,
• payments in progress,
• disputed and overdue receivables and liabilities.

Source documents

• sales and purchase invoices for the period,
• bank statements and transfer confirmations,
• contracts, leasing and car documents,
• employee and payroll documentation (if applicable),
• official decisions, interpretations and inspection results,
• correspondence with the authorities.

Powers of attorney and access

• list of current powers of attorney: UPL-1, PEL, or PPO-1/PPS-1,
• confirmation of appeals (OPL-1, PEL-O), if they have already been submitted,
• list of people with access to KSeF - see KSeF permissions for an accountant,
• access to the bank, invoicing program, cloud, company email,
• date of planned receipt of individual accesses.

Do not disable access before downloading all UPOs and exports. Don't leave unlimited rights at the end of the contract.

Official data

• settlements, overpayments and arrears visible in the e-Tax Office and the current tax microaccount number,
• PUE/eZUS balances and individual contribution account,
• overpayments, arrears, active installment arrangements,
• status of open inspections and proceedings.

Receive data in a usable format

PDF declarations themselves will not replace accounting data. It is worth entering the file formats in the protocol:

• export of KPiR or revenue records (CSV, XML, PDF),
• JPK and UPO files,
• list of entries of fixed assets,
• contractor and settlement files,
• opening balance and turnover and balances with full books,
• source files that can be imported into a new program.

The new office should confirm that the files can be opened and reconciled before the old access is closed.

How to carry out a handover step by step

1. Set a cut-off date and last month scope in writing.
2. Prepare a table of border obligations: who sends the last JPK, who settles ZUS, who closes the month.
3. Ask your current office for data export and a list of documents for the cut-off date.
4. Receive files in a usable format (not just PDF).
5. Check if exports open and reconcile with DTTs and balances.
6. Prepare a protocol with specific items from the checklist above.
7. Give the new office permissions (UPL-1, PEL, KSeF) - only to the extent it needs.
8. Revoke the powers of attorney of the previous office (OPL-1, PEL-O) only after sending the last declarations and receiving the UPO.
9. Receive access to the bank, program, cloud and email after confirming the completeness of the transfer.

The most common mistakes

1. The protocol is written vaguely: "accounting transferred."
2. No cut-off date or the date described in words.
3. Receipt of only PDF files without accounting data.
4. No UPO in the list.
5. Keeping UPL-1, PEL and access to KSeF active at the former office.
6. Disabling access before downloading exports.
7. Lack of reconciliation of balances with the e-Office and ZUS on the cut-off date.
8. Lack of copies of the protocol and attachments on both sides.
9. No indication of who is responsible for historical corrections.

When the previous office does not issue data

1. Send a written request with a specific list of documents and a deadline.
2. Reference the contract, ownership of documents and storage obligations specific to a given collection.
3. Secure data available in KSeF, e-Office, ZUS, bank and your own program.
4. Don't wait with current settlements.
5. In case of a dispute, use legal assistance and the office's liability insurance, if the damage is covered.

Sources

• Biznes.gov.pl - tax powers of attorney (UPL-1, OPL-1)
• ZUS - power of attorney PEL
• ZUS - PEL-O application for appeal
• Ministry of Finance - tax power of attorney forms
• VAT Act - ELI, in particular Art. 100 regarding VAT-EU information.

The material is of a general nature. The detailed procedure for transferring documents results from the contract, the form of records, powers of attorney and the scope of company data.