The Polish Minister of Finance and Economy signed the amending Regulation on the detailed scope of data contained in tax declarations and records for VAT (JPK_VAT with declaration), which is now awaiting official publication.
As previously reported, this regulation adapts JPK_VAT reporting to the mandatory KSeF 2.0 framework. Taxpayers will be required to include KSeF invoice numbers or the appropriate markers in both sales and purchase records of JPK_VAT with declaration for filing periods starting 1 February 2026.
Confirmed Requirements
KSeF Number Reporting: Taxpayers must report the KSeF invoice number in JPK_VAT sales and purchase records for all invoices issued and received via KSeF, regardless of the mode used (online, offline24, offline (unavailability), or failure), based on the status at the time of filing.
Document Markers: New markers apply for invoices and documents that do not have a KSeF number:
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OFF — failure mode invoice without a KSeF number at the time of filing
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BFK — electronic or paper invoice issued outside KSeF (non-KSeF invoices)
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DI — offline24 and offline (unavailability) mode invoice without a KSeF number at the time of filing or document other than a KSeF invoice
MoF Clarifications
In response to business concerns raised during public consultations, the Ministry of Finance provided the following clarifications:
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Limited correction obligation: It is not required to correct records to add KSeF numbers for invoices that lacked one at filing, except for sales invoices issued in offline24 or offline (unavailability) mode (Art. 106nda or Art. 106nh) that receive a KSeF number after JPK_VAT submission. The MoF notes that such cases will be “sporadic,” since these invoices must be sent to KSeF the next business day after issuance and will therefore typically have a KSeF number before the JPK_VAT filing deadline.
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Purchase records: There is no requirement to correct purchase records to add the KSeF number if the invoice did not have one at filing time.
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Correction rules unchanged: As under current rules, taxpayers may correct JPK_VAT errors after identifying them, or following a request from the tax office. Penalties are not automatic and cases will continue to be considered on a case-by-case basis.
What’s Next
The regulation was signed on 12 December 2025 and is awaiting publication in the Journal of Laws. Draft JPK_VAT logical structures are already available.
Businesses should ensure their systems are updated to capture and report KSeF invoice numbers in JPK_VAT records, and to apply the appropriate markers by 1 February 2026.
Want to understand more about e-invoicing requirements in Poland and how they will impact your business? Read our Sovos e-invoicing in Poland: B2B, B2G, KSeF dedicated webpage.
For future updates on Poland and similar developments in other countries, follow our Regulatory Analysis page.
