The Polish Ministry of Finance has published a new draft regulation outlining the integration requirements between JPK_VAT with declaration returns and the National e-Invoicing System (KSeF), which becomes mandatory on 1 February 2026. Under the new requirements, taxpayers must report KSeF invoice numbers in their JPK_VAT from the same date KSeF becomes mandatory, with no transition period for adaptation.
New Requirements from 1 February 2026
Mandatory KSeF Number Reporting
All invoices must include KSeF numbers in JPK_VAT submissions for both sales and purchases.
Document Markings When KSeF Numbers Unavailable
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OFF – Invoices issued during KSeF system outages
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BFK – Paper/electronic (non-structured) invoices when KSeF exemptions apply
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DI – Other documents and offline24 invoices without KSeF numbers
Correction Obligations
Taxpayers must correct JPK_VAT filings when invoices marked “OFF” or “DI” subsequently receive KSeF numbers.
Impact on Businesses
This acceleration means organizations must be ready for both KSeF compliance and updated JPK_VAT reporting simultaneously. There will be no adaptation period to gradually align reporting processes.
The draft regulation applies uniformly to all taxpayers required to use KSeF, regardless of their specific KSeF implementation date under the phased rollout. Therefore, the requirement to include KSeF numbers or the applicable markings in their JPK_VAT applies from 1 February 2026 for all taxpayers.
Next Steps
Although this is still a draft regulation pending final publication, given the short timeline until 1 February 2026 and the planned elimination of the transition period, businesses should prepare for JPK_VAT compliance with KSeF requirements as soon as possible.
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.
