Planned changes to JPK VAT

On 24 October 2023, the Ministry published a bill of amendment to the Regulation on detailed scope of data included in tax returns and records for the tax on goods and services.

The purpose of the bill is to implement changes that adapt the provisions of the Regulation on JPK_VAT with Declaration and make them more precise so that they are compatible with the obligations relating to the National e-Invoice System.

The crucial changes presented in the bill consist of:

  • inclusion of an invoice number to identify invoices in the National e-Invoice System, and
  • identification of invoices issued throughout the term of KseF accessibility and during the period of inaccessibility of this system also in a situation where issuance of an invoice in KSeF was not possible for reasons attributable to the taxpayer (new identifiers in JPK: “BFF”, “OFF”).

Apart from the above provisions, the bill also contains a number of changes that make the Regulation more precise. These consist primarily of changes in the terminology, which is to limit potential doubts that may arise when the provisions take effect.

This is another amendment to the legislation connected with the obligatory KSeF that is to take effect on 1 July 2024, which is to enable tax authorities to promptly identify documents issued and received by taxpayers with account being taken of the manner of their recognition and accounting for in JPK_VAT with a declaration.

The bill is currently subject to evaluation. Comments concerning its provisions can be submitted by 14 November 2023.

Should you have any questions or doubts regarding the issues discussed here, we are ready to help you. Feel free to contact us.


Elżbieta Lis Partner, Katowice

T: +48 32 731 68 58
M: +48 664 948 038

Adam Książek Manager | Legal advisor, Katowice

T: +48 32 731 68 78

Aleksandra Kalinowska Partner, Warsaw

T: +48 22 690 08 70
M: +48 724 440 693

Katarzyna Chrapowicka Director, Warsaw

T: +48 22 690 08 88