Statutory Auditor and a Sole Proprietorship (JDG) in Poland 2026 — When a Financial Statement Audit Is Required
A statutory auditor and a sole proprietorship (JDG) in 2026. When an audit is mandatory, revenue thresholds, financial statements, costs, pitfalls. A practical guide.
A statutory auditor (biegły rewident) is associated with large companies — but at some point your sole proprietorship's (JDG) revenue may grow enough that an audit becomes mandatory. When does this happen and what must you do?
In this guide I explain when a sole proprietorship (JDG) needs a statutory auditor and what this means for your accounting.
Statutory auditor — full accounting and audit thresholds
In Poland, mandatory full accounting (financial books) starts at 2M EUR turnover. Mandatory audit of financial statements by a statutory auditor occurs at 5M EUR turnover. These are two separate thresholds — full accounting does not automatically mean an audit.
Two thresholds
Audit criteria (2 of 3)
Audit is mandatory when a company meets at least 2 of 3 criteria in the given and previous year:
A sole proprietorship (JDG) is generally not subject to mandatory audit because it keeps simplified accounting (PKPiR). However, a JDG can voluntarily switch to full accounting and, if criteria are met, also undergo an audit.
Important: Capital companies (sp. z o.o., S.A.) always keep full accounting regardless of turnover. Audit is mandatory for public companies, banks, insurers, and entities above the thresholds. The 2M EUR threshold for full accounting applies to JDG and partnerships.
Let's check if your company requires full accounting or an audit.
Let's talk →Full accounting: Art. 2(1)(2) of the Accounting Act (2M EUR threshold). Audit: Art. 2(1)(3) and annex (5M EUR threshold). Audit criteria: Ministry of Finance regulation. JDG: Freedom of Economic Activity Act. Legal status: 2026.
When does a sole proprietorship (JDG) need a statutory auditor?
General rule
A sole proprietorship (JDG) as a legal form is not subject to the obligation to audit financial statements. This obligation applies to companies (spółka z o.o., S.A.), not to a sole proprietorship.
But note: if your JDG has high revenue, you may be obligated to maintain full accounting — and then financial statements are subject to audit if they exceed the thresholds.
Audit thresholds (for entities covered by full accounting)
A mandatory audit of the financial statement occurs when at least 2 of 3 criteria are met:
- Average annual employment ≥ 50 employees
- Total assets ≥ 2,5 mln EUR (~10 750 000 zł)
- Annual net revenue ≥ 5 mln EUR (~21 500 000 zł)
In 2026, 5 mln EUR ≈ 21 500 000 zł.
When does a JDG switch to full accounting?
A sole proprietorship (JDG) must switch from the KPiR (tax revenue and expense book) to full accounting if it exceeds at least 2 of 3 thresholds:
- Average annual employment ≥ 50
- Annual net revenue ≥ 2 mln EUR (~8 600 000 zł)
- Total assets ≥ 1 mln EUR (~4 300 000 zł)
If your JDG exceeds these thresholds, you must maintain full accounting (ledger accounts, balance sheet, profit and loss statement).
Does a JDG itself need an audit?
Short answer: usually no.
A sole proprietorship (JDG) (as a natural person running a business) maintains a KPiR (tax revenue and expense book) or full accounting. An audit is mandatory only for:
- Limited liability companies (spółka z o.o.)
- Joint-stock companies (S.A.)
- Limited and general partnerships (in specific cases)
- Entities maintaining full accounting that exceed the audit thresholds
A JDG that exceeds the full-accounting thresholds but is not a company does NOT need a statutory auditor — unless it voluntarily commissions an audit.
Exception: civil and professional partnerships
If you run a civil partnership or a professional partnership, an audit may be mandatory if the thresholds are exceeded. Then the audit is commissioned for the partnership, not for each partner's JDG individually.
When is a voluntary audit worthwhile?
Even if you don't have to, an audit can be useful:
1. Obtaining financing
Banks and investors may require an audited financial statement for a loan or investment.
2. Selling the company
If you plan to sell the business or transform it into a company, an audit increases credibility and facilitates valuation.
3. Disputes with the tax office
In a dispute with the tax office about income, an external audit can serve as evidence of the correctness of your settlements.
4. Counterparty requirements
Some B2B counterparties (especially foreign ones) require audited statements from suppliers.
Costs of a statutory auditor
Mandatory audit
Audit costs depend on the size of the company:
- Small company (revenue < 5 mln EUR): 5 000–10 000 zł
- Medium company (5–10 mln EUR): 10 000–20 000 zł
- Large company (> 10 mln EUR): 20 000–50 000 zł+
Voluntary audit
Costs are similar to a mandatory audit — they depend on scope and complexity.
Pitfalls
1. Switching to full accounting without an audit
Many entrepreneurs exceed the full-accounting thresholds but are unaware of the obligation. If you do not switch to full accounting on time, penalties may apply.
2. An audit does not replace accounting
An audit verifies the correctness of the financial statement — but it is not accounting. You still need an accountant to maintain current bookkeeping.
3. A statutory auditor is not a tax advisor
A statutory auditor verifies accounting but does not advise on tax matters. For tax optimization you need a tax advisor.
4. Missing documentation
Missing source documents (invoices, contracts, confirmations) is the most common reason a statutory auditor issues a qualified opinion. Keep all documents for 5 years.
5. Ryczałt and full accounting
On lump-sum tax (ryczałt) you record only revenue, but if you exceed the full-accounting thresholds you must maintain full accounting (ledger accounts, balance sheet) — ryczałt does not exempt you from this obligation.
FAQ
I have a JDG with 3 mln zł in revenue. Do I need a statutory auditor?
No. 3 mln zł < 2 mln EUR (the full-accounting threshold), so you remain on the KPiR (tax revenue and expense book). An audit is not mandatory.
Can I exceed the full-accounting threshold and still maintain a KPiR?
No. If you exceed at least 2 of 3 thresholds (employment, revenue, assets), you must switch to full accounting the following year.
Is an audit mandatory for a JDG on ryczałt with 15 mln zł in revenue?
A JDG on ryczałt with 15 mln zł in revenue > 2 mln EUR → must switch to full accounting. But whether the statement audit is required depends on the audit thresholds (5 mln EUR revenue). 15 mln zł ≈ 3,5 mln EUR < 5 mln EUR → an audit is not mandatory (if the other criteria are also not met).
Must a statutory auditor be a Polish citizen?
No. A statutory auditor must be listed on the register of statutory auditors maintained by the Polish Audit Oversight Agency (PANA). They may be a foreign national.
Need help?
Oxyok accounting — from 49 zł + VAT per month. We will help you determine whether you are approaching the full-accounting thresholds, how to prepare for an audit, and how to optimize costs.
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Disclaimer: Audit thresholds and requirements are valid in 2026. This article is informational in nature — before making a decision, consult an accountant or a statutory auditor.
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