CRS-1(4) Schema: Poland’s New CRS Form From 1 December 2026
On 9 November 2026 the Polish National Revenue Administration (KAS) updated its “Struktury CRS” page to publish the CRS-1(4) schema, labelled as applying from 1 December 2026 for reporting years from 2016. The same page now marks CRS-1(3), the schema for reporting years from 2019, and CRS-1(2), the schema for 2016 to 2018, as valid until 30 November 2026. Read together, those labels leave CRS-1(4) as the only CRS-1 structure listed for any message a Polish reporting financial institution sends from December, whether it carries a new year’s data or corrects an old one.
The schema is the technical half of a legal change already in force. The Act of 13 February 2026 amending the Act on the exchange of tax information with other countries (Dziennik Ustaw 2026, item 347) took effect on 18 March 2026 and rewrote art. 34, the list of what the annual information on reportable accounts contains, as part of implementing Council Directive (EU) 2023/2226. CRS-1(4) gives the new art. 34 data items a place in the XML and adds transitional account codes for accounts opened between 1 January and 17 March 2026.
Related reading: how Germany’s BZSt is moving its CRS filers to schema v3.0
CRS-1(4) dates and form versions
| Date | What happens | Source |
|---|---|---|
| 17 March 2026 | Amending act published as Dziennik Ustaw 2026, item 347; in force from the following day, 18 March 2026 | Act of 13 February 2026, art. 13 |
| 30 June 2026 | Deadline for 2025 reportable-account information, for which art. 5(1) preserves the pre-amendment reporting procedures | Exchange of tax information act, art. 33(1); 2026 act, art. 5(1) |
| 9 November 2026 | KAS updates the Struktury CRS page (version 10.0) with schemat_CRS-1(4).xsd | KAS Struktury CRS page |
| 30 November 2026 | Last day of validity for CRS-1(3) and CRS-1(2) | KAS Struktury CRS page |
| 1 December 2026 | CRS-1(4) applies, for reporting years from 2016 | KAS Struktury CRS page |
| 30 June 2027 | Deadline for the 2026 information, the first year under the amended art. 34 (art. 5(1) read with art. 33(1)) | Exchange of tax information act, art. 33(1); 2026 act, art. 5(1) |
The 30 June deadline did not move. Art. 33(1) of the Act of 9 March 2017 sets it for reportable accounts, art. 36(1) for undocumented accounts, and the 2026 act left both untouched. Filing remains electronic only, through the KAS Formularze system.
One CRS-1(4) schema for every reporting year from 2016
The header and year rules differ from CRS-1(3). In CRS-1(4) the attribute kodSystemowy is fixed to “CRS-1 (4)”, wersjaSchemy stays “1-0E”, WariantFormularza moves from 3 to 4, and the target namespace is http://crd.gov.pl/wzor/2026/10/30/14415/. The Rok element sets a minimum year of 2016 and no maximum of its own; any upper cap comes from the imported etd:TRok base type. CRS-1(3) restricted the same element to 2019 to 2030, which is why years 2016 to 2018 needed CRS-1(2).
The consolidation matters for routing. A late or corrected 2018 record sent in 2027 goes on the same structure as the 2026 annual file, and a routing table that still maps “2016 to 2018” to CRS-1(2) after 30 November produces a message on a schema KAS no longer lists as valid.
The imported shared dictionaries also changed. CRS-1(4) imports the KodyKrajow country code list version 14-0E (dated 11 August 2026), a KodyISOFatca list version 1-0E for currency codes, and StrukturyDanych version 12-0E, where CRS-1(3) imported KodyCechKrajow version 3-0E and StrukturyDanych version 5-0E. The size limits carry over: a Deklaracja holds up to 100 CRS blocks of up to 500 AccountReport elements each, in both versions.
New CRS-1(4) fields and the amended art. 34 items behind them
Each new element in the CRS-1(4) schema traces to a data item the 2026 act added to art. 34. The element names and code families in the KAS XSD follow the OECD’s CRS XML Schema v3.0, documented in the OECD’s Amended CRS XML Schema User Guide (version 4.0, October 2024). The occurrence constraints and allowed values in the table are read from the KAS XSD; the OECD guide is a reference for the code meanings, and the amended art. 34 sets the substantive information requirements.
| CRS-1(4) element | Allowed values | Statutory item (art. 34 as amended) |
|---|---|---|
| AccountHolder / SelfCert (mandatory) | CRS901 true, CRS902 false, CRS900 not reported | Art. 34(1)(1)(a) and (b): whether the holder provided a current self-certification |
| ControllingPerson / CtrlgPersonType (now mandatory, repeatable) | CRS801 to CRS813, CRS800 not reported | Art. 34(1)(1)(c): role or roles as controlling person |
| ControllingPerson / SelfCert (mandatory) | CRS1001 true, CRS1002 false, CRS1000 not reported | Art. 34(1)(1)(c): self-certification for each reportable controlling person |
| AccountHolder / EquityInterestType (optional, repeatable) | CRS401 to CRS410 | Art. 34(1)(8): roles of an equity interest holder in an investment entity that is a legal arrangement |
| AccountType (mandatory) | CRS1101 to CRS1104, CRS1100 not reported | Art. 34(1)(2)(b): type of account |
| DDProcedure (mandatory) | CRS1201 new, CRS1202 preexisting, CRS1200 not reported | Art. 34(1)(2)(c): new or preexisting account |
| JointAccount (optional element in the KAS XSD) / Number (required once JointAccount is present) | Integer 1 to 200 (maxInclusive and minInclusive in the KAS XSD) | Art. 34(1)(2)(d): joint holding and number of joint holders |
In the XSD, JointAccount has minOccurs 0. Art. 34(1)(2)(d) requires the joint-holding status and the number of joint holders to be reported, so a jointly held account carries the JointAccount element with its Number.
The AccountNumber attribute AcctNumberType also gains OECD606, “Specified Electronic Money Product”. The code matches the accounts holding electronic money that the 2026 act added to the depository account definition in art. 24(1)(37)(g).
The DDProcedure flag follows the amended definitions in art. 24(1), not the opening date alone. An account held on 31 December 2025 that was outside the old financial account definition (for example, one that qualifies only because the 2026 act added e-money accounts to art. 24(1)(37)) counts as preexisting under art. 24(1)(11)(a). A new account under art. 24(1)(15) is one opened from 1 January 2016 to 31 December 2025 that already qualified under the old rules, or any account opened after 31 December 2025, unless art. 24(1)(11)(b) treats it as preexisting. An opening-date rule keyed only to 2016 misclassifies the first group.
Transitional account codes 3 and 4: the January to March 2026 window
In AccountTreatment, each AccountReport still chooses between Przejsciowy (a transitional account code) and Inny (fixed “yes” for every other account). CRS-1(3) offered two transitional codes, described only as accounts opened in “the transitional period” with or without a self-certification. CRS-1(4) names two windows: codes 1 and 2 for accounts opened from 1 January 2016 to 30 April 2017, and new codes 3 and 4 for accounts opened from 1 January 2026 to 17 March 2026, each pair split by whether a self-certification was obtained.
The second window ends the day before the 2026 act took effect. Art. 5(3) of that act requires a reporting financial institution to obtain a self-certification without delay, and to apply new-account due diligence, for a new account opened in that window that was not a financial account under the old wording of the act. Under art. 5(4), where such an account closed before 18 March 2026 and the request for a self-certification failed, preexisting-account procedures apply instead.
The schema annotation describes codes 3 and 4 only by opening date and self-certification status, without the statutory limit to accounts outside the old definition. The statute limits the art. 5(3) population to accounts outside the old definition; the KAS materials checked do not say whether an ordinary deposit account opened in February 2026, already a financial account under the old rules, should carry code 3 or 4, or Inny.
Corrections to 2016 to 2025 data after 30 November
Art. 5(1) of the 2026 act keeps the pre-amendment rules for the 2025 information, which was due by 30 June 2026 and filed on CRS-1(3).
On the page’s validity labels, a correction to any year from 2016 to 2025 sent on or after 1 December 2026 has to be built on CRS-1(4). Historical records may lack some of the additional information the amended rules require. The schema includes five “not reported” values (CRS800, CRS900, CRS1000, CRS1100 and CRS1200), each annotated as a transitional measure for interoperability with the previous schema version, particularly for corrections. Their use depends on the information actually available and on the CRS-1(4) validation and filing rules; they are not a default for every year before 2026, so correction logic needs a documented rule for when a code is used instead of available data; our CRS reporting in Luxembourg guide walks through the wider annual CRS cycle for comparison.
Role codes under the electronically searchable data relief
Art. 5(2) of the 2026 act narrows the new role obligations for older accounts. For a reportable account maintained on 31 December 2025, and for reporting periods ending no later than 31 December 2027, the controlling person roles in art. 34(1)(1)(c) and the equity interest roles in art. 34(1)(8) need to be reported only where that information is available in electronically searchable data held by the reporting financial institution.
In the XSD, EquityInterestType has minOccurs 0. Art. 34(1)(8) requires the applicable equity-interest holder role or roles for investment entities that are legal arrangements, subject to the limited electronically searchable data relief above. CtrlgPersonType is mandatory for every ControllingPerson in CRS-1(4), where CRS-1(3) allowed it to be omitted. The OECD guide prints its equivalent relief text under CtrlgPersonType and lists CRS800 there, without stating that CRS800 is the value to use for relief cases.
KAS has not filled that gap yet, and the Struktury CRS page listed no CRS-1(4) filing guide in its 9 November 2026 version. Which value a Polish filer should send for a controlling person whose role sits outside searchable data in the 2026 and 2027 reporting periods remains an open question.
Frequently Asked Questions
Does CRS-1(4) introduce a nil return for years with no reportable accounts?
The schema defines a CrsMessageTypeIndic code list that includes CRS703, “no data to report”, but no element in CRS-1(4) uses it, and CRS-1(3) was built the same way. Under art. 33(4) and art. 36(3), a reporting financial institution that identifies no reportable or undocumented accounts does not file.
Does every e-money account now appear in the CRS-1 file?
The 2026 act added an excluded account category in art. 31(2)(8): an e-money depository account under art. 24(1)(37)(g) is excluded if the 90-day rolling average of its aggregate end-of-day balance or value, over any period of 90 consecutive days, did not exceed USD 10,000 on any day of the calendar year. An e-money account that does not qualify for the art. 31(2)(8) exclusion remains subject to the other account exclusions, classification and due-diligence requirements, and is reportable where those rules establish a reportable account, including any applicable controlling-person reporting.
Related Articles
- BZSt CRS Reporting: The Schema v3.0 Switch and Saint-Martin Refile: Germany’s move to CRS XML schema v3.0.
- CRS Reporting in Luxembourg: the annual CRS cycle for Luxembourg financial institutions.
- CARF Reporting in Luxembourg: DAC8 Crypto Filing by 30 June: the crypto-asset reporting side of DAC8.
- Poland GloBE Top-Up Tax Filing: What the Ministry’s Q&A Settles: Polish GLB-D1 and GIR filing questions.
Key Takeaways
- An account held on 31 December 2025 that became a financial account only under the amended definitions gets DDProcedure CRS1202 (preexisting) under art. 24(1)(11)(a), whatever its opening date.
- Tagging accounts opened from 1 January to 17 March 2026 now, with self-certification status, lets codes 3 or 4 be assigned once KAS confirms their scope.
- For controlling persons on accounts held at 31 December 2025, recording whether each role came from electronically searchable data evidences the art. 5(2) relief through reporting periods ending 31 December 2027.
- The only filing guide on the Struktury CRS page, updated 18 May 2022, covers CRS-1(2) and CRS-1(3); a CRS-1(4) guide is the publication to watch for.
Sources and References
- KAS, Struktury CRS (page version 10.0, 9 November 2026): https://www.gov.pl/web/kas/struktury-crs
- KAS, schemat_CRS-1(4).xsd: https://www.gov.pl/attachment/f38db979-7be4-4143-9275-6b515a73c4e6
- KAS, schemat_CRS-1(3).xsd: https://www.gov.pl/attachment/1f7cae19-4060-4218-ba5e-96c877c6e2ea
- Act of 13 February 2026 amending the Act on the exchange of tax information with other countries, Dziennik Ustaw 2026, item 347: https://api.sejm.gov.pl/eli/acts/DU/2026/347/text.pdf
- Act of 9 March 2017 on the exchange of tax information with other countries, consolidated text, Dziennik Ustaw 2025, item 1379: https://api.sejm.gov.pl/eli/acts/DU/2025/1379/text.pdf
- Council Directive (EU) 2023/2226 of 17 October 2023 (DAC8): https://eur-lex.europa.eu/eli/dir/2023/2226/oj/eng
- OECD, Amended Common Reporting Standard XML Schema: User Guide for Tax Administrations, version 4.0 (October 2024): https://www.oecd.org/content/dam/oecd/en/publications/reports/2024/10/amended-common-reporting-standard-xml-schema_27960161/dd7ee57a-en.pdf
- OECD CRS XML Schema v3.0 (copy published by the Finnish Tax Administration): https://vero.fi/contentassets/c3dcde0af9374153aada7e6c63f4cfcc/crsxml_v3.0.xsd
- podatki.gov.pl, Automatyczna wymiana informacji: https://www.podatki.gov.pl/podatkowa-wspolpraca-miedzynarodowa/automatyczna-wymiana-informacji
CRS-1(4) build checkpoints before 1 December 2026 and 30 June 2027
The two dates to plan around are 1 December 2026, after which KAS lists no other CRS-1 schema for any year, and 30 June 2027, when the first annual file with the amended art. 34 content falls due. The decision to take now is how the build populates CtrlgPersonType and transitional codes 3 and 4 until KAS publishes a CRS-1(4) filing guide.
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