JPK_VAT: new markings and mandatory KSeF number from February 1, 2026.
On October 14, 2025, a draft amendment to the regulation on the detailed scope of data contained in JPK_VAT with a declaration was published on the website of the Government Legislation Center. The draft introduces the obligation to clearly mark each sales and purchase item with a KSeF number or one of three new markings (OFF, BFK, DI) from February 1, 2026.
New markings in the JPK_VAT records
With the implementation of the mandatory KSeF, taxpayers will be required to include the invoice identification number in KSeF (the so-called KSeF number) in their records.
If, at the time of submitting JPK_VAT, this number has not yet been assigned or the invoice has not been sent to KSeF, the taxpayer will be required to use one of three new markings:
- OFF – for invoices issued during a KSeF failure (Article 106nf of the VAT Act) which, at the time of submitting JPK_VAT, do not have an identification number or have not yet been sent to the system.
- BFK – for invoices issued outside KSeF, in electronic or paper form (e.g., in cases of exemptions from the obligation to use KSeF).
- DI – for documents other than invoices, including customs documents, internal evidence (WEW), periodic reports (RO), and invoices issued offline, which do not yet have a KSeF number or have not been sent to the system. Once obtained, the taxpayer corrects the records and completes the data.
The existing markings (RO, WEW, FP, VAT_RR, MK) remain unchanged and will be used in parallel.
Practical significance of the new designations
The designation “DI” in particular raises many doubts, as it may require correction of the JPK_VAT after obtaining the KSeF number. In practice, this obligation may prove to be an additional administrative burden for taxpayers.
On the purchase side
With regard to purchase invoices issued offline, this obligation seems to be moderately severe, because, according to the regulations, these invoices in the B2B formula are considered received only when they are sent to KSeF. This means that only invoices that already have a KSeF number will be included in the purchase records.
However, the period without sanctions may be problematic, as some taxpayers may, for example, send invoices that do not meet the KSeF requirements (thus suggesting that they are invoices issued outside KSeF – to be marked as “BFK”) and then subsequently consider them to be offline invoices sent after the deadline. At the same time, a situation may arise where an invoice is marked by the buyer as “DI” but never reaches KSeF, which should result in its designation being changed to “BFK.” According to the presented assumptions, these cases give rise to an obligation to make changes on the part of the buyer.
On the sales side
In practice, the need for correction may also arise on the sales side, for example, when an invoice is issued in the last days of the month and the JPK_VAT for that period is sent before the KSeF number is assigned.
Foreign entities (registered for VAT purposes without a permanent place of business)
It is also worth noting that the obligation to use the new markings will also apply to foreign entities that do not have a registered office or permanent place of business in Poland.
This raises legitimate concerns about how the KSeF number will be reported in their JPK_VAT records, particularly from the perspective of how this number is obtained. Potentially, either OCR-type tools will have to be extended with such functionality, or these entities will be indirectly forced to enter the optional KSeF for the purchasing side.
Changes to the deposit system
The draft regulation adapts the structure of JPK_VAT with a declaration to the rules for settling unreturned deposits in the deposit system.
Entities introducing products covered by the deposit system will report in JPK_VAT – in accordance with the provisions of the Act – VAT due on unrecovered deposits by increasing the tax base in the declaration part of the file.
At the same time, in accordance with the Act, the tax is paid by the entity representing the deposit system, acting as the payer.
The draft regulation provides for a modification of the JPK_VAT scheme with a declaration in this respect, so as to enable the correct recording of data related to the deposit system.
Summary
The changes are intended to ensure full consistency between VAT records and KSeF data. In practice, this means that accounting systems and reporting processes will have to be adapted so that each invoice or document in the VAT records is clearly assigned to the correct designation.
Scope of support
The Andersen Tax & Legal team supports taxpayers in preparing for the implementation of new obligations in the area of JPK_VAT and KSeF.
Our support includes, in particular:
- analysis of invoicing and reporting processes in ERP systems,
- development of document and data mapping logic in JPK_VAT structures,
- testing of data compliance with the requirements of the new schemes,
- development and implementation of internal procedures for file verification and correction.
Thanks to our teams’ experience in the area of VAT and KSeF compliance, we help clients effectively adapt their reporting systems and processes to the upcoming changes.
If you have any questions or need to discuss the impact of the new regulations on your organization’s operations, we are at your disposal.
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