Document Handover Protocol When Changing Accountants in Poland in 2026

A document handover protocol is a written inventory of what one accounting office transfers to another when their engagement ends. There is no single official form or mandatory template. In a dispute, however, it provides straightforward evidence of exactly what was transferred, to whom, and when.

This article expands the “handover protocol” section of the guide on how to change accountants in Poland in 2026 with a specific checklist. Related topics include UPL-1 — power of attorney for electronic tax returns and PEL — power of attorney for social insurance (ZUS).

What the protocol is — and what it is not

A handover protocol is an internal, bilateral document drawn up by the former and new accounting offices, or by the former office and the business owner. It serves three purposes:

• it lists specific data sets, periods, and formats,
• it identifies the handover cut-off date,
• it confirms that the parties know who is responsible for each period.

What the protocol is not:

• a mandatory official form — no statute provides one,
• a substitute for notifications to the business registry (CEIDG), ZUS, or the tax office,
• automatic protection against liability for the predecessor’s errors,
• in itself, the legal basis for releasing documents in a dispute — the contract and document-retention rules apply there.

The protocol is an organisational tool, not a source of law. It is worth having, but its strength depends on how specific its entries are.

Protocol contents — full checklist

The list below is the minimum that should appear in a handover protocol. Every item requires specific details: the period, number of entries, file format, and submission status.

Details of the parties

• full details of the former accounting office and the business owner,
• full details of the new accounting office,
• the date and place where the protocol was prepared,
• the signatures of both parties,
• any attachments, such as inventories, exports, and confirmations.

Cut-off date

• the specific day — preferably the last day of a month — through which the former office is responsible for the records,
• the day from which the new records begin,
• an indication of who books documents dated within the cut-off period.

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

Accounting records

• the tax revenue and expense book (KPiR), or revenue register broken down by month,
• accounting books — balance sheet, profit and loss account, turnover and balances — for full accounting,
• sales and purchase VAT registers,
• fixed-asset and intangible-asset registers,
• the equipment inventory, if one was maintained,
• counterparty and settlement ledgers,
• stocktakes and inventory sheets.

For more on fixed-asset records, see the fixed-asset register for a sole proprietorship and fixed-asset depreciation for a sole proprietorship.

Returns and JPK files

• JPK_V7 for every month; for quarterly settlements, also the correct declaration sections of JPK_V7K for the month ending the quarter,
• VAT-UE for every month in which the obligation to file the information arose,
• withholding-agent returns and information, such as PIT-8AR and PIT-4R, if the business employs staff,
• annual income tax returns: PIT-36, PIT-36L, or PIT-28,
• corrections to submitted returns,
• for details of a submitted JPK_V7, see JPK_V7 for a sole proprietorship.

Do not ask for “VAT-7” or “PIT-5.” JPK_V7 replaced VAT-7, while PIT-5 is not a monthly advance-payment return for a sole proprietorship. The PIT advance is calculated and paid without filing a return.

UPOs and confirmations

• an official receipt confirmation (UPO) for every electronic return and JPK file submitted,
• confirmations of ZUS document submissions, including DRA, RCA, and RSA,
• official confirmations of submission or delivery (UPP/UPD), depending on the channel used.

A PDF of a return is not the same as a UPO. Without a UPO, you have no evidence that the return actually reached the authority and was accepted.

Fixed assets

• asset records showing the date placed in service, initial value, depreciation rate, and method,
• depreciation charges recorded to date,
• a list of assets not yet fully depreciated,
• purchase documents and any disposal documents.

Settlements and balances

• open counterparty items,
• balances as at the cut-off date,
• unsettled advance payments and receipts,
• payments in progress,
• disputed and overdue receivables and liabilities.

Source documents

• sales and purchase invoices for the period,
• bank statements and transfer confirmations,
• contracts, leases, and vehicle documents,
• employee and payroll documentation, where applicable,
• official decisions, tax rulings, and audit findings,
• correspondence with public authorities.

Powers of attorney and access rights

• a list of current powers of attorney: UPL-1, PEL, and PPO-1/PPS-1 where applicable,
• confirmations of revocation, such as OPL-1 and PEL-O, if already filed,
• a list of people with access to the national e-invoicing system (KSeF) — see KSeF permissions for an accountant,
• access to the bank, invoicing software, cloud storage, and business email,
• the planned date for revoking each access right.

Do not disable access before downloading all UPOs and exports. Do not leave unrestricted permissions in place after the contract ends.

Official account information

• balances in the e-Tax Office and the individual tax account,
• balances in PUE/eZUS and the individual contribution account,
• overpayments, arrears, and active instalment arrangements,
• the status of open audits and proceedings.

Receiving data in a usable format

PDFs of returns alone do not replace accounting data. The protocol should state the file formats:

• an export of the KPiR or revenue register in CSV, XML, or PDF,
• JPK files and UPOs,
• fixed-asset record reports,
• counterparty and settlement ledgers,
• the opening balance and turnover and balances for full accounting,
• source files that can be imported into the new software.

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

How to conduct the handover step by step

1. Agree in writing on the cut-off date and the scope of the final month.
2. Prepare a table of cut-off responsibilities: who submits the final JPK, who accounts for ZUS, and who closes the month.
3. Ask the former office for a data export and an inventory of documents as at the cut-off date.
4. Receive the files in a usable format, not only as PDFs.
5. Check that the exports open and reconcile with the UPOs and balances.
6. Draw up the protocol with specific items from the checklist above.
7. Grant the new office the necessary UPL-1, PEL, and KSeF permissions — only to the extent it needs them.
8. Revoke the former office’s powers of attorney through OPL-1 and PEL-O only after the final returns have been submitted and the UPOs collected.
9. Revoke access to the bank, software, cloud storage, and email after confirming that the handover is complete.

Common mistakes

1. Using a vague protocol entry such as “bookkeeping handed over.”
2. Omitting the cut-off date or describing it only in words.
3. Receiving PDFs only, without accounting data.
4. Omitting UPOs from the inventory.
5. Leaving the former office’s UPL-1, PEL, and KSeF access active.
6. Disabling access before downloading exports.
7. Failing to reconcile e-Tax Office and ZUS balances on the cut-off date.
8. Failing to retain a copy of the protocol and attachments for both parties.
9. Failing to state who is responsible for historical corrections.

When the former office refuses to release the data

1. Send a written demand with a specific list of documents and a deadline.
2. Refer to the contract, ownership of the documents, and the retention obligations applicable to each data set.
3. Secure the data available in KSeF, the e-Tax Office, ZUS, the bank, and your own software.
4. Do not postpone current filings and settlements.
5. In a dispute, obtain legal assistance and consider the office’s professional indemnity insurance if it covers the loss.

Sources

• Biznes.gov.pl — tax powers of attorney (UPL-1, OPL-1)
• ZUS — PEL power of attorney
• ZUS — PEL-O revocation form
• Ministry of Finance — tax power-of-attorney forms
• Polish VAT Act — ELI, in particular Article 100 on VAT-UE information.

This material is general in nature. The detailed handover procedure depends on the contract, the form of record-keeping, the powers of attorney, and the scope of the business’s data.