Poland: Draft Amendment to JPK_VAT Regulation to Align with KSeF

The Polish Ministry of Finance and Economy has published a draft amendment to the regulation on the detailed scope of data included in tax returns and VAT records, aiming to align the JPK_VAT (SAF-T) structure with the National e-Invoicing System (KSeF). The proposal, presented at the Government Legislation Centre on 10 October 2025, introduces new reporting obligations for both sellers and buyers, in preparation for the upcoming full implementation of KSeF by February 2026.

Key Amendments and New Markings in JPK_VAT

According to the draft, all invoices issued through KSeF will need to include a unique KSeF number ("NrKSeF"). Where the number is unavailable at the time of submission, taxpayers must apply one of the following designations:

• OFF – for invoices issued during a KSeF system outage, not yet assigned a KSeF number;
• BFK – for electronic or paper invoices issued outside KSeF;
• DI – for other documents, including invoices issued in “offline24” mode.

In addition, buyers will be required to include the KSeF number in their purchase records — a previously optional element. The regulation also introduces reporting rules for unrefunded deposits on beverage packaging, following amendments to the Packaging Management Act. These deposits will now have to be reflected in the JPK_VAT file and declaration, even though payment responsibility rests with the representing entity under Article 17b of the VAT Act.

Scope and Timeline of the New JPK_VAT

The updated regulation provides for changes to §§ 3, 4, 10 and 11 of the current JPK_VAT regulation. The obligation to report the KSeF number in both sales and purchase records will apply from 1 February 2026. Transitional provisions allow data on deposits and simplified invoices to continue to be reported under current rules until the end of December 2026.

The new reporting structure will affect all taxpayers — including smaller entities and foreign companies registered for VAT in Poland, even those not yet obliged to issue invoices through KSeF. Experts have warned that the three-month window before mandatory KSeF implementation may be insufficient to implement the necessary system changes.

The draft regulation — “Ordinance of the Minister of Finance and Economy amending the regulation on the detailed scope of data included in tax returns and VAT records” (Draft of 10 October 2025) — and its accompanying Justification are available on the . Also, the .

Learn more about Polish JPK (SAF-T) in our dedicated VAT manual for Poland.

How Marosa Can Support Your Transition

Adapting to the new JPK_VAT requirements and the integration with KSeF will require updates to your invoicing and VAT reporting processes. Marosa offers expert assistance to help businesses understand and implement these changes efficiently. Through VATify, our cloud-based VAT compliance platform, companies can automate VAT return preparation, integrate structured data from e-invoicing systems, and ensure their reporting aligns with Poland’s evolving SAF-T and KSeF obligations.