Poland Issues Updated Guidance on JPK_VAT Document Tags

The Polish Ministry of Finance has released updated guidance clarifying how taxpayers must use new document tags in the sales and purchase records of the JPK_VAT with declaration (Polish Standard Audit File for VAT). Beginning with the February 2026 reporting period, all taxpayers must utilize these mandatory fields within their sales and purchase ledgers, regardless of their specific onboarding timeline for the National e-Invoicing System (KSeF). Consequently, businesses scheduled to transition to mandatory e-invoicing later – including those with a January 1, 2027 deadline – are still required to implement these markings.

New Document Markings in JPK_VAT and Scope of Application

The guidance outlines four specific entries or tags to be used in the KSeF-related data fields, depending on how and when an invoice was issued:

• NrKSeF: The KSeF ID must be provided for any invoice issued through KSeF that has been assigned an official system ID by the JPK_VAT filing date. This requirement applies regardless of the issuing mode, including offline24, failure, and system unavailability modes, as long as the document has been assigned a KSeF ID.
• OFF: This tag is designated for invoices issued during an official KSeF technical failure mode (under Article 106nf(1) of the VAT Act) that lack an assigned KSeF ID when submitted. Taxpayers are not required to amend their JPK_VAT records once the KSeF number is generated retroactively.
• BFK: This applies to traditional paper or electronic invoices generated entirely outside the KSeF platform. This includes documentation issued before a taxpayer’s mandatory KSeF implementation date or during total system failures (under Article 106ng of the VAT Act).
• DI: This identifier is used for alternative documentation types not covered by the OFF or BFK tags, such as internal accounting documents or aggregated retail data from cash registers. It also applies to invoices prepared during system unavailability or specific offline modes that have not received a KSeF ID by the filing date. Once these offline invoices retroactively receive their KSeF ID, businesses must submit a JPK_VAT correction to replace the 'DI' tag with the actual KSeF number.

The detailed guidelines are accessible on the official KSeF website in Polish.

There’s more you should know about e-invoicing in Poland – learn more about the new and upcoming regulations.