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Comprehensive Support in respect of Acquirers’ reporting obligation (ITP/ITP-Z)

Polish Reporting Obligation (ITP/ITP-Z) for Payment Transactions

The requirement to report payment transaction data (ITP/ITP-Z) has transitioned from a temporary measure to a permanent feature within Polish law. With an increased focus on monitoring transactions and ensuring market transparency, the tax authorities are actively identifying entities that do not comply, mainly targeting foreign entities.

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Key details on the reporting requirements

  • The ITP reporting obligation was introduced to Polish regulations in January 2023. The deadline for submitting the first report was January 15, 2023 (including data for the period from July 1, 2022, to December 31, 2022).
  • As of April 1, 2025, the requirement to submit paymenttransaction information –processed through payment terminals,software, or IT systems – has been permanently incorporatedinto Polish law.
  • Acquirers are required to submit the ITP information monthly to the tax authorities –electronically and in a structured format.
  • The reporting obligation arises exclusively from domestic legislation and is independent of other reporting requirements, such as the Central Electronic System of Payment Information (CESOP), and is much more detailed and specific to the Polish market.
  • The tax authorities may impose a penalty of up to PLN 700,000 (approx. EUR 160,000) on an entity for failing to meet ITP reporting obligations.

Entities Required to Verify Obligations for Reporting ITP/ITP-Z Information to the Tax Authority:

  • Entities that provide payment services within Poland.
  • Entities that offer acquiring services within Poland.

If an entity's business involves the categories mentioned above,it is essential to review reporting obligations to ensure full compliance with current regulations and avoid potential penalties.

  • We offer assistance in analyzing the ITP reporting obligation.
  • If such an obligation applies, we can support the preparation and submission of the ITP report in a compliant and timely manner – both for past periods and future periods.
  • We actively facilitate communication with the tax authorities. If the report is submitted after the deadline, we can help manage the proceedings to potentially reduce penalties.

Contacts:

Jakub Żak

Jakub Żak

Partner, Lider Zespołu Doradztwa Podatkowego dla Instytucji Finansowych
Przemysław Borowiec

Przemysław Borowiec

Dyrektor w Zespole Doradztwa Podatkowego dla Instytucji Finansowych
+48 225 110 479
Dariusz Osada

Dariusz Osada

Doradca Podatkowy, Radca Prawny w Zespole Doradztwa Podatkowego dla Instytucji Finansowych
+ 48 795 425 448