Questions and answers
How to send a file with records?
The records are sent via the service interfaces of the Standard Audit File (JPK Gateway) https://e-dokumenty.mf.gov.pl. Via the website https://kwd.mf.gov.pl/cesop/start or https://kwd.mf.gov.pl/client.
In order to send records, the Payment Service Provider must register using the registration form and indicate the persons authorized to upload files to the Central Electronic Information System for Payments (CESOP).
A test environment has also been made available. All necessary information needed to connect to the test environment can be found in the specifications available on our website.
Who is authorized to sign and send records?
The person authorized to sign and send the file is the person indicated by the payment service provider in the registration form to perform this type of activities.
According to the assumptions of the system, the Payment Service Provider must provide an XML file consistent with the registration scheme used to indicate persons authorized to send records, via the JPK gateway or a dedicated registration form. The supplier must report at least one person authorized to send files to CESOP.
The signature placed on the sent records will be verified with the signature registered via the registration scheme.
The registration scheme should be signed by a person authorized to represent the supplier, indicated in the National Court Register, or by a representative.
When will it be possible to register for reporting to CESOP?
Registration for reporting in the CESOP system started in April 2024.
Is zero reporting (nihil reporting) obligatory? (i.e. records containing no transactions or fewer than 25 transactions per quarter)
In accordance with applicable regulations, a payment service provider is obliged to report only when it completes more than 25 transactions to the same payment recipient in a given Member State during a calendar quarter. Importantly, reports containing fewer transactions should not be sent. The exception is zero reports. This will ensure clarity and transparency of reporting. We recommend to send zero reports.
How long does the verification of the payment service provider's registration (PSP-FR) last to enable the reporting process?
Verification of a submitted registration form will take place without undue delay, no longer than 7 days. After positive verification of the registration form, the Payment Service Provider (PSP) will be able to send the records.
What is the size limit of files sent to the CESOP?
Limit depends on communication. For website services it is up to 100 MB. There is no such limit while reporting via software application (API).
What types of signature can be used to sign reports?
Qualified signature and Trusted Profile.
In Poland, we accept qualified signatures compliant with the eIDAS standard included on the list eIDAS Dashboard (europa.eu).
How to submit a correction to the report for a given period? Do we re-report the full record or only corrected records?
Correction is only made to records that need correction. The correction file contains a field referring to the original declaration.
How will the payment service provider receive confirmation of the submission of a report?
After sending the record file, the PSP will receive a reference number that will allow to check the sending status. After proper verification of the logical structure and the correctness of the data and electronic signature, the PSP will receive an Official Confirmation of Receipt (UPO). In case of incorrect validation, PSP will receive an error report.
How long will it take to resend the records if the file is rejected?
The PSP has time to submit the report by the end of the month following a given quarter. If the records are rejected, the PSP should send the correct file without undue delay.
Will the published reporting schema be modify?
The reporting scheme was developed by the European Commission team and is uniform for all member states. Modifications to the scheme can only be made at the level of the European Commission. Every updated schema will be published on our website.
Can a penalty be imposed for no submition data to CESOP when the PSP is obliged for reporting?
The CESOP reporting is a tax information form, therefore failure to submit it on time or at all may result in fiscal penal liability and constitute a fiscal offense.
The penalty for a fiscal offense is a fine ranging from 1/10 to 20 times the amount of the minimum wage.
How to send the registration form (PSP-FR for foreign PSP)?
- Complete the registration form (PSP-FR) on the website and save it or prepare an XML file yourself, compliant with the PSP-FR schema.
- Go to the "Sign and Send" tab.
- Upload the generated or prepared XML file.
- Generate files for upload (remember that these are two files: zip and initupload.xml). The file with the zip extension will have the name of the report form file with the XML extension.
- Sign the initupload.xml file as represented.
Upload the zip and initupload.xml files into the appropriate fields in the "Send" tab. Enter the email address to which the confirmation will be sent and click send.
A detailed description of the sending can be found in the CESOP User Manual - Taxpayer Application.
The VAT number is not required because the main identifier of the PSP is the bank identification code (BIC).
To complete a registration process you need to send a registration documents of PSP with translation to polish and your proxy given by a proper board member(s) entitled to represent a company. Please send it to cesop@mf.gov.pl.
When this step is done you can send a xml file (made according to XSD scheme) via https://kwd.mf.gov.pl/cesop/start.
Can one PSP submit CESOP reports on behalf of another PSP?
The XML schema allows entity B to submit a report on behalf of entity A. At no level will the validator verify the relationship between entities A and B.
Both entities may appoint the same representative who will sign and send the records.
Can an attorney be authorized to sign the registration form (power of attorney based on the PPS-1 form)?
In the light of the general principle expressed in Art. 138a § 1 of the Tax Ordinance, a party may act through a proxy, unless the nature of the activity requires its personal action.
The registration form is to be signed by the payment service provider in accordance with its representation in the National Court Register or the relevant foreign register.
It should be noted that in relation to the submission of this form, there is no requirement for personal action by the obligated payment service provider, e.g. in the form of a reservation that it is not permissible to sign this form by a proxy.
Therefore, the registration form may be submitted and signed by an authorized representative on behalf of the payment service provider.
Such a representative may be:
- a general representative who is authorized to act in all tax matters and in other matters falling within the jurisdiction of tax authorities (Article 138d § 1 of the Tax Ordinance) or
- a special proxy who is authorized to act in a specified tax matter or another specified matter falling within the jurisdiction of the tax authority (Article 138e § 1 of the Tax Ordinance) - the scope of such a special power of attorney (PoA) may therefore include submitting and signing the CESOP registration form.
Please send the PoA to cesop@mf.gov.pl.
Does receiving an official confirmation of receipt (UPO) after sending the PSP-FR mean that the file has been verified and accepted, and the proxy has been correctly appointed?
UPO in the CESOP Taxpayer Application User Manual is defined as a document confirming receipt of the file by the Ministry of Finance, issued in the absence of technical and business validation errors.
If the file is technically correct, the JPK gateway will return code 200 and UPO. However, receiving a UPO does not mean that a representative has been properly appointed.
Receiving a UPO after sending the PSP-FR means that the file has been accepted for verification. Information that the file has been verified will be sent within 7 days of sending it electronically to the email address provided in the registration form. If the file was rejected (e.g. due to being signed by a person not authorized to represent the entity), the PSP-FR should be submitted again.
Does functional file splitting allow you to split Payee into 2 different XML files - to avoid the file exceeding 200 MB?
Yes, functional file splitting allows you to divide the report into several files.
Is the file division (due to its size) automatic when loading the file in the tool in accordance with the provision "The generated document will be compressed into a ZIP file and divided binary into parts with a size not exceeding 60 MB"?
The technical division only occurs when declarations are sent via an application software interface (API). Then the large file will be divided into smaller ones for sending to the JPK gateway.
When using the website, there is a limit of 100 MB uncompressed file size. Functional file division should be used.
Files larger than 1 GB will be rejected at EU level.
How to correctly fill in the field values in the electronic signature?
Correctly completed identification data of the representative using a qualified electronic signature are the data of the holder of the electronic signature, e.g. name/names and surname.
A correctly completed field "Serial number provided in the proxy signature certificate identifier" should contain only the number, without additional descriptions. The serial number appears after the equals sign (=) in the SERIALNUMBER value in the Subject field. You should only enter the value after the "equals" sign.
Error 407, what does it mean and what to do when it occurs?
Error code 407 indicates a duplicate.
Once an XML file compliant with the PSP-FR schema is generated, it cannot be submitted a second time.
However, in order to resend the records, you need to change some value in the PSP-FR form, e.g. enter an optional field or change the order of the representatives if there is more than one, and then it will be possible to generate two zip and initupload.xml files again. This will allow you to sign the initupload.xml file according to its representation and then send it.
What to do if you have problems submitting a form or report?
If you receive the message: "Failed to send document! Due to technical reasons, we were unable to send your document. Please try again or return to home page” the first step is to check the metadata of the initupload.xml file. Please remember that this file must comply with the applicable scheme and be signed in accordance with the instructions. The metadata file (initupload.xml) must be digitally signed with a qualified Polish or European signature or a trusted signature in accordance with the XAdES Basic Electronic Signature algorithm in the form of an XML file consistent with the scheme http://www.w3.org/2000/09/xmldsig, in XAdES-BES in short: Enveloped (signature as an additional ds:Signature element in the original XML) or Enveloping (original document included as an element in the signed structure). To be sure about your signature settings, please contact your signature provider.
Error 420, what does it mean and what to do when it occurs?
Error code 420 indicates a discrepancy between the data entered in the registration form and the data sent in the report.
The entity identifier (Reporting PSP) from the report is compared with the entity identifier from the registration form and the Serial Number field provided in the proxy signature certificate identifier with the SERIALNUMBER value of the qualified certificate.
The values of these fields must be the same, otherwise the power of attorney granted in the registration form cannot be found.
If an error occurs, please check whether the PSP-FR form has been completed correctly. If the data is corrected, please correct the form and resend it.
If there is still a problem with the shipment, please send the shipment ID to cesop@mf.gov.pl for verification.