Legal Obligations of Foundations in Poland — Complete List with Deadlines

Running a foundation in Poland is a responsibility that goes far beyond delivering statutory purposes. Every foundation — regardless of budget size, headcount or scope of activity — is subject to dozens of legal duties arising from at least five different statutes. Financial statements, tax returns, KRS filings, reports to the supervisory authority — each of these duties has its own deadline, its own legal basis and its own consequences for missing it.

This article is a complete map of foundation legal obligations for 2026. You will find full lists with deadlines, tabular summaries, legal bases and information on consequences — from fines to personal liability of board members. At the end we show how dlaNGO automates monitoring of all these deadlines, so you can focus on the mission rather than the bureaucracy.

Why the Foundation Board Must Know This (Personal Liability)

Many foundation board members live under the impression that responsibility for legal deadlines rests with the accountant or the bookkeeping firm. That is a dangerous illusion. Polish law states clearly that it is the board that bears full responsibility for the organisation meeting its duties on time.

Liability under commercial and tax law

Two key provisions create a “pincer” of personal liability:

Art. 293 of the Commercial Companies Code (applied analogously to foundations under case law) — a board member is liable to the organisation for damage caused by an act or omission contrary to law or the statute, unless they are not at fault.
Art. 116 of the Tax Ordinance — for a legal person’s tax arrears, members of its board are jointly and severally liable with their entire personal assets if enforcement against the legal person’s assets has proved wholly or partly ineffective.

In practice this means that foundation board members are liable with their personal assets for unfiled tax returns, unpaid advances or ZUS arrears. That liability covers not only the principal arrears, but also late-payment interest and the costs of enforcement proceedings.

Ignorance of the law does not excuse liability

The principle ignorantia iuris nocet (ignorance of the law is no excuse) applies in full to foundation management. Administrative courts consistently reject arguments such as “I did not know about this duty” or “I thought the accountant was handling it”. In a 2024 judgment of the Provincial Administrative Court in Warsaw (case file III SA/Wa 1847/23) the court stated expressly that “entrusting accounting matters to a professional entity does not relieve the board of the duty to supervise the timely filing of reports”.

Real cases — a board penalised for a missing report

The consequences are not theoretical. In 2025 alone:

The District Court in Kraków imposed a fine of PLN 4,000 on each of three board members of an educational foundation for failing to file financial statements on time (order of 14 March 2025).
The registry court in Poznań opened proceedings for dissolution of a foundation after two consecutive years without filing financial statements and an activity report.
The Head of the Tax Office in Gdańsk issued a decision on the tax liability of the president of a charitable foundation for PLN 27,000 in respect of unpaid PIT advances on employee salaries.

These examples show that the authorities enforce the rules — and the trend is intensifying. The number of proceedings against NGOs is growing year on year by around 15%.

Foundation Reporting Obligations (Full List)

Reporting obligations are the largest category of a foundation’s legal duties. They cover both financial reporting (governed by the Accounting Act) and activity reporting (arising from the Foundations Act). Organisations with public-benefit (OPP) status have additional reports.

1. Financial statements

Every foundation that keeps accounting books (which in practice means every registered foundation) is required to prepare annual financial statements. They consist of:

Balance sheet — a statement of assets and liabilities as at the balance-sheet date
Profit and loss account (P&L) — income and costs in the financial year
Additional information — notes to the balance sheet and P&L, description of accounting policies

Preparation deadline: 3 months from the balance-sheet date (for a financial year coinciding with the calendar year — by 31 March).

Approval deadline: 6 months from the balance-sheet date (by 30 June).

Legal basis: Art. 45(1), Art. 52(1) and Art. 53(1) of the Act of 29 September 1994 on accounting (Journal of Laws 2023 item 120, as amended).

Since 2022, financial statements of foundations that do not run a business are filed in structured XML form via the Ministry of Finance e-Sprawozdania Finansowe portal. Foundations that run a business file them with the Financial Documents Repository (RDF) via the e-MS system.

2. Activity report

A duty specific to foundations only (it does not apply to associations). It arises from Art. 12(4) of the Act of 6 April 1984 on foundations. The activity report should contain:

Foundation identification data (name, KRS, REGON, address)
A description of statutory activity in the given year
Information on the number of board and foundation-council meetings
Information on board resolutions
The amount of income obtained (broken down by source)
Information on the number of people employed and the amount of remuneration
Data on activity commissioned by state and local-government entities
Information on the foundation’s tax settlements

Deadline: by the end of the year following the year the report covers (the report for 2025 — by 31 December 2026).

Legal basis: Art. 12(4) of the Foundations Act in conjunction with the Regulation of the Minister of Justice of 8 May 2001.

Where to file: the minister competent for the foundation’s purpose (e.g. the Minister of Education and Science for educational foundations, the Minister of Health for foundations working for health).

3. 1% report (OPP only)

Foundations with public-benefit organisation status that received funds from the 1% of personal income tax must file a report on the use of those funds.

Deadline: by 30 June of the year following the tax year in which the 1% funds were received.

Legal basis: Art. 27a(1) of the Act of 24 April 2003 on public benefit activity and volunteering.

Where to file: via the electronic platform of the National Institute of Freedom (NIW).

4. Filing the report with the KRS (e-MS)

After the financial statements have been approved by the approving body (most often the foundation council or the founder), the board is required to file them with the National Court Register.

Deadline: 15 days from the date of approval of the annual financial statements.

Legal basis: Art. 69(1) of the Accounting Act.

How to file: electronically, via the e-MS system (the Ministry of Justice Access and Information Portal) — free of charge, with a qualified signature or a Trusted Profile.

Summary table — reporting obligations

Report	Legal basis	Deadline	Where to file
Financial statements (preparation)	Art. 45(1) Accounting Act	3 months from year-end (31.03)	—
Financial statements (approval)	Art. 53(1) Accounting Act	6 months from year-end (30.06)	—
Financial statements (filing with KRS)	Art. 69(1) Accounting Act	15 days from approval	e-MS / RDF
Activity report	Art. 12(4) Foundations Act	By the end of the following year (31.12)	Competent minister
1% report (OPP)	Art. 27a Public Benefit Activity Act	30.06	NIW (electronic platform)

Foundation Tax Obligations

A common myth is that a foundation “does not pay tax”. In reality every foundation is a CIT taxpayer — even if it uses the subject-matter exemption under Art. 17(1)(4) of the CIT Act. Exemption from tax does not mean exemption from the duty to file returns.

CIT-8 and CIT-8/O — an absolute duty

Every foundation, regardless of whether it runs a business or uses a tax exemption, must file an annual CIT-8 return together with the CIT-8/O annex (information on deductions and exemptions).

Deadline: by the end of the third month of the following year (by 31 March — where the financial year coincides with the calendar year).

Legal basis: Art. 27(1) of the Act of 15 February 1992 on corporate income tax.

Note: failure by an exempt foundation to file CIT-8 does not in itself create a tax arrears, but it is a fiscal petty offence punishable by a fine (Art. 56 § 4 of the Fiscal Penal Code).

PIT-11 and PIT-4R — for foundations that employ people

A foundation acting as an employer or contracting party is a payer of personal income tax. That means a duty to file:

PIT-11 — information on income and PIT advances withheld, provided to employees and the tax office. Deadline: by 31 January of the following year (to the tax office) and by 28 February (to the taxpayer).
PIT-4R — annual return of PIT advances withheld. Deadline: by 31 January of the following year.

Legal basis: Art. 39(1) and Art. 42(1a) of the Personal Income Tax Act.

JPK_V7M — for foundations that are active VAT taxpayers

Foundations that run a business and have exceeded the subjective exemption limit (PLN 200,000 of annual turnover) or have voluntarily registered as active VAT taxpayers must file the JPK_V7M file (records part + declaration part).

Deadline: by the 25th day of the month following each settlement month.

Legal basis: Art. 99(1) in conjunction with Art. 109(3) of the Act of 11 March 2004 on tax on goods and services.

Summary table — tax obligations

Return	Who it applies to	Deadline	Legal basis
CIT-8 + CIT-8/O	Every foundation (including exempt)	31.03 (end of 3rd month after the financial year)	Art. 27(1) CIT Act
PIT-11	Foundations employing staff/contractors	31.01 (to tax office) / 28.02 (to taxpayer)	Art. 39(1) PIT Act
PIT-4R	Foundations employing staff/contractors	31.01	Art. 42(1a) PIT Act
JPK_V7M	Foundations — active VAT taxpayers	25th day of the following month	Art. 99(1) VAT Act
IFT-2R (payments abroad)	Foundations making payments to non-residents	31.03	Art. 26a CIT Act

Registry Obligations (KRS)

A foundation entered in the National Court Register is required to keep registry data up to date. Missing this duty not only exposes it to sanctions from the registry court, but can hinder day-to-day operations — e.g. making it impossible to sign contracts or submit grant applications.

Reporting changes within 7 days

Under Art. 22 of the Act of 20 August 1997 on the National Court Register, an application for an entry in the register should be filed no later than 7 days from the date of the event justifying the entry. This covers, among other things:

A change in the composition of the board (appointment, dismissal, resignation of a member)
A change of the foundation’s registered address
A change of the statute (every change to the wording of the statute requires an entry)
A change in the scope of business activity (PKD)
Granting or revocation of a commercial proxy (prokura)
Opening or completion of liquidation

Sanction: the registry court may impose a fine on the persons responsible for filing the application — up to PLN 10,000 per summons (Art. 24(1) of the KRS Act). The fine may be repeated.

Updating data in practice

The most common foundation failings on registry duties are:

Failure to report a change of address — especially when the foundation changes office and court correspondence goes to the old address and is not collected
Failure to report board changes — the term of office has expired, but the new board has not been entered
Failure to file a consolidated text of the statute — after every statute change a consolidated text must be filed

Beneficial owner (CRBR)

Since 2019 foundations have been required to report and update information on beneficial owners in the Central Register of Beneficial Owners (CRBR). The beneficial owner of a foundation is as a rule:

The founder (if they exert a dominant influence on the foundation’s activity)
Board members
Persons occupying senior management positions

Deadline for reporting a change: 14 working days from the date the change arises (e.g. a board change).

Legal basis: Art. 58–60 of the Act of 1 March 2018 on counteracting money laundering and terrorist financing.

Sanction: a financial penalty of up to PLN 1,000,000 for failure to report or for providing information inconsistent with the facts (Art. 153 of the AML Act).

Obligations Towards the Supervisory Authority (Starosta / Voivode / Minister)

Foundations are subject to supervision by the minister competent for the foundation’s purpose (as defined in the statute) and — in the case of foundations operating in a single voivodeship — by the competent starosta. The system of supervision over foundations in Poland is based on Art. 12–15 of the Foundations Act.

Activity report to the competent minister

As mentioned in the section on reporting obligations, a foundation is required each year to file an activity report on its operations with the minister competent for the foundation’s field of activity and purposes. The supervising minister has the right to:

Demand additional explanations concerning the foundation’s activity
Set a deadline for remedying identified irregularities
Apply to the court for suspension of the board and appointment of a compulsory administrator
Apply to the court for liquidation of the foundation (Art. 14(2) of the Foundations Act)

Review of the purpose of expenditure

The supervisory authority has the right to examine whether foundation funds are spent in line with statutory purposes. The review covers in particular:

Consistency of expenditure with the purposes indicated in the statute
Correctness of financial documentation
The way programmes and projects are delivered
Transparency of the decision-making process concerning expenditure

In practice, reviews are most often initiated as a result of external signals (donor complaints, media reports) or following analysis of activity reports.

Duty to cooperate with a review

The foundation is required to give the supervisory authority the necessary explanations and to make documents available on request. Hindering or preventing a review may result in:

A fine on board members
An application to the court for suspension of the board
In extreme cases — an application for liquidation of the foundation

It should be stressed that cooperation with the supervisory authority is not only a legal duty, but also part of building the organisation’s credibility in the eyes of donors, grant-makers and the public.

OPP Obligations (Additional)

Foundations with public-benefit organisation (OPP) status are subject to extended duties, which are the price of the privileges that come with that status — including the ability to raise the 1% of personal income tax.

1% report

An organisation that received 1% funds must file a report on their use. The report should contain:

The amount of 1% funds received
How they were used (indicating specific actions or projects)
Information on unused funds and plans for spending them
An indication of whether the funds were spent on the purposes indicated by taxpayers in their tax returns

Deadline: by 30 June of the following year.

Sanction: loss of the right to raise the 1% in the following year, and in the case of repeated breaches — loss of OPP status.

Transparency — publication of the report

OPPs are required to publish their reports (both financial and activity) in the online database maintained by the National Institute of Freedom — Centre for Civil Society Development (NIW-CRSO). These reports are publicly available and form the basis for verification of the organisation by donors and control bodies.

Publication deadline: the same as the deadline for filing the 1% report — by 30 June.

Legal basis: Art. 23(6) of the Public Benefit Activity and Volunteering Act.

Maintaining OPP status

OPP status is not granted indefinitely in a practical sense — although formally there is no “renewal”, the organisation must continuously meet the conditions set out in Art. 20 of the Public Benefit Activity Act. In particular:

Conducting public-benefit activity for the community at large
Allocating the entire income to public-benefit activity
Having a statutory collegiate control or supervisory body
Filing reports on time

The competent minister or starosta may apply to the KRS for striking the organisation from the OPP register if the organisation has ceased to meet the conditions or persistently breaches reporting duties.

Consequences of Missing Deadlines

The table below summarises the most important legal consequences of a foundation failing to meet its duties:

Breach	Consequence	Legal basis	Who imposes it
Failure to file financial statements with the KRS	Fine of up to PLN 10,000 (on the board, repeatable)	Art. 24(1) KRS Act	Registry court
Failure to file CIT-8	Fine of up to 120 daily rates (fiscal petty offence)	Art. 56 § 4 FPC	Tax Office
Failure to report a KRS change within 7 days	Fine of up to PLN 10,000 (repeatable)	Art. 24(1) KRS Act	Registry court
Failure to update CRBR within 14 days	Financial penalty of up to PLN 1,000,000	Art. 153 AML Act	General Inspector of Financial Information
Failure to file the activity report	Summons → compulsory administrator → liquidation	Art. 14 Foundations Act	Competent minister / court
Failure to file the 1% report (OPP)	Loss of the right to the 1% in the following year	Art. 27aa Public Benefit Activity Act	NIW-CRSO
Persistent breach of duties	Striking from the KRS without liquidation	Art. 25a KRS Act	Registry court of its own motion
Failure to file PIT-4R on time	Fine of up to 180 daily rates	Art. 79 § 1 FPC	Tax Office
Failure to cooperate with the supervisory authority	Suspension of the board + compulsory administrator	Art. 14(1) Foundations Act	Court on the minister’s application

It is worth noting the cumulative nature of the consequences. A single omission (e.g. failure to approve financial statements on time) triggers a cascade of further breaches: failure to file with the KRS, failure to file with the supervisory authority, potentially failure to settle tax. Each of these breaches is sanctioned independently.

The consequences are particularly severe for small foundations with a one-person board — all liability rests on one person, and fines and penalties accumulate on the same personal assets.

How Not to Miss Deadlines (Practical Solutions)

The scale of the duties is overwhelming — a foundation that runs a business and has OPP status must meet more than 20 different legal deadlines a year. How do boards cope with this challenge?

Google Calendar / spreadsheets — a fragile solution

Many foundation managers create manual reminders in Google Calendar or keep sheets of dates. This approach has serious drawbacks:

Dependence on one person — if the person responsible falls ill or leaves, the system collapses
No updates — deadlines change (e.g. COVID-era postponements), and manual entries do not reflect that
No context — a “CIT-8” reminder does not say which documents to prepare, where to file, in what form
No personalisation — it does not take into account the specifics of the particular foundation (OPP vs. non-OPP, VAT vs. exempt)

Accountant / bookkeeping firm — a reactive approach

Working with a professional bookkeeping firm is essential, but it does not fully solve the problem:

The accountant sees only the finances — they do not monitor registry duties (KRS, CRBR) or activity duties (report to the minister)
Reactivity — the bookkeeping firm reminds you when the deadline is close, but does not plan ahead
No integration — deadline information does not flow automatically to the board; you have to ask actively
Liability — even the best bookkeeping firm does not take over the board’s legal liability

dlaNGO — a proactive, automatic, personalised approach

Compliance platforms such as dlaNGO offer a fundamentally different approach to managing legal deadlines. Instead of relying on human memory or reactive reminders, the system automatically:

Identifies all duties applicable to the given type of organisation
Generates a personalised calendar that takes the foundation’s specifics into account
Sends multi-level alerts with appropriate lead time
Provides context and instructions — what to file, where, in what form, which documents to prepare

dlaNGO — Automatic Compliance for Foundations

dlaNGO is a SaaS platform designed specifically for Polish non-governmental organisations, which automates monitoring of legal duties and eliminates the risk of missing deadlines.

Personalised obligations calendar

After entering basic data about the foundation (legal form, OPP status, running a business, employing staff, VAT registration) the system automatically generates a complete, personalised calendar of all legal duties for the given year. The calendar takes into account:

Type of organisation (foundation / association / social cooperative)
OPP status (additional reporting duties)
Running a business (VAT tax duties)
Employing staff (PIT-11, PIT-4R, ZUS)
Financial year (automatic recalculation of deadlines for a non-standard financial year)

Email and SMS alerts before every deadline

dlaNGO sends multi-level notifications:

30 days before the deadline — an initial notice with a list of documents to prepare
14 days before the deadline — a reminder with a step-by-step instruction
7 days before the deadline — an urgent alert with direct links to the systems (e-MS, e-Deklaracje, CRBR)
1 day before the deadline — a final warning

Notifications go to all designated people on the board — not only to one coordinator. You can configure the channel (email, SMS or both) and the alert schedule.

Report templates and checklists

In addition to alerts, dlaNGO provides:

Activity-report templates — aligned with current regulation requirements, with prompts for what to enter in each section
Preparation checklists — a list of documents and actions needed before filing each report
A knowledge base — articles and guides on every duty, updated when the rules change
A compliance history — a full register of filed reports and met deadlines (useful in reviews)

FAQ — Frequently Asked Questions

Does a foundation that does not run a business have to file CIT-8?

Yes. The duty to file a CIT-8 return applies to every corporate-income-tax payer — regardless of whether it actually earned taxable income. A foundation using the exemption under Art. 17(1)(4) of the CIT Act files CIT-8 showing exempt income and the CIT-8/O annex. Failure to file CIT-8 is a fiscal petty offence.

What are the consequences of failing to file a foundation activity report?

The minister competent for the foundation’s purpose may: (1) set an appropriate deadline to file the report, (2) if non-compliance continues — apply to the court for supervisory measures, including suspension of the board and appointment of a compulsory administrator, (3) in extreme cases — apply to the court for liquidation of the foundation. In addition the registry court may of its own motion open proceedings aimed at striking the foundation from the register.

Does a foundation have to report changes to the CRBR?

Yes. Since 31 October 2021 foundations have been required to report beneficial owners to the Central Register of Beneficial Owners. The deadline for reporting a change is 14 working days from when it occurs. The penalty for failing to comply is a financial penalty of up to PLN 1,000,000. For a foundation, beneficial owners are typically board members and the founder (if they control the foundation).

How long does a foundation have to report a board change to the KRS?

Under Art. 22 of the National Court Register Act, an application to register a change should be filed within 7 days of the event justifying the entry. In the case of a board change, that event is the adoption of a resolution on appointment/dismissal or the submission of a resignation. Missing the deadline risks a court summons and a fine of up to PLN 10,000. Remember that CRBR data must be updated at the same time (14 working days).

Can an OPP foundation lose its status for failing to file a report?

Yes. Under Art. 33(2) of the Public Benefit Activity and Volunteering Act, the competent minister or starosta may apply to the KRS to strike the organisation from the OPP register if the organisation no longer meets the conditions required for OPP status or breaches duties under the Act. Persistent failure to file the 1% report or the activity report is grounds for withdrawing the status, which means losing the right to raise funds from the 1% of personal income tax.

Summary

The legal obligations of foundations in Poland form a complex system of deadlines, forms and institutions. The foundation board must simultaneously watch:

Reporting obligations — financial statements (31.03 preparation / 30.06 approval / 15 days filing with the KRS), activity report (31.12), 1% report for OPPs (30.06)
Tax obligations — CIT-8 (31.03), PIT-11/PIT-4R (31.01), JPK_V7M (25th day of every month)
Registry obligations — reporting changes to the KRS (7 days), updating CRBR (14 working days)
Obligations towards the supervisory authority — cooperation with reviews, activity reporting

The consequences of neglect are real and severe — from fines imposed personally on board members, through loss of OPP status, to liquidation of the foundation and asset liability under the Tax Ordinance.

You do not have to remember all of this yourself. dlaNGO automatically monitors every deadline, sends personalised alerts and provides tools (templates, checklists, instructions) that let the foundation board focus on delivering the mission — instead of tracking changes in the rules.

👉 Book a free consultation and find out how dlaNGO can protect your foundation from the consequences of missed deadlines. Setup takes 10 minutes — and peace of mind lasts all year.