Official Guidance on JPK and KSeF Issued by the Polish Ministry of Finance: Understanding the New Tax Reporting Protocols
In April 2026, the Polish Ministry of Finance released crucial official guidance concerning the updated regulations for the Standard Audit File for Tax (SAF-T) for VAT—specifically, JPK_V7(3). This update marks a significant shift in how invoices must be reported in JPK. The guidance was published shortly after comprehensive information appeared on government websites regarding JPK and KSeF.
Background: The New JPK_V7(3)
Effective February 1, 2026, JPK_V7(3) introduces essential changes to improve interoperability between the JPK and KSeF. Notably, this new version mandates that each invoice reported in the JPK must now align with its function within KSeF. This necessitates that any invoice that has received a KSeF number must include this identifier in the JPK submission. Conversely, if an invoice lacks a KSeF number, the taxpayer must indicate the reason for its absence using one of the following designations: OFF, BF, or DI.
Clarifying Designation Doubts: April 2026 Official Guidance
As businesses scrambled to comply with the updated requirements, uncertainties emerged about how to designate specific tax entries correctly, particularly regarding the import of services and the intracommunity acquisition of goods. This led to confusion about whether these entries should be designated as BFK or DI.
To alleviate these concerns, the Ministry of Finance provided essential clarification through its official guidance released in April 2026. This guidance is particularly relevant for taxpayers navigating complex international trade scenarios, where proper documentation and reporting are vital.
Key Highlights of the Guidance
1. Role of KSeF Numbers
The guidance emphasizes that all invoices assigned a KSeF number must be reported accordingly in the JPK. This streamlines the reporting process, reducing room for error and enhancing data integrity.
2. New Designations
The Ministry specified the correct designation to use in varying circumstances:
- OFF: is used when an invoice was issued during an official KSeF outage and no number has yet been assigned in the system at the time the JPK is submitted.
- BF: when the entry is based on an invoice issued outside the KSeF, e.g., issued during a complete KSeF outage, issued outside the KSeF by taxpayers who are not required to issue invoices using the KSeF, issued in connection with intra-Community acquisition of goods and importation of services, electronic or paper invoices issued using cash registers, fiscal receipts treated as invoices.
- DI: Applied to documents other than invoices (e.g. internal documents, summary sales documents from cash registers, invoices issued offline24 and during system downtime that do not have a KSeF number as of the date the records are submitted)
3. Service Imports and Intracommunity Acquisitions
The guidance clarifies that taxpayers should categorize service imports and intracommunity acquisitions of goods as BFK documented with an invoice outside the KSeF system. While the DI tag is used for records relating to intra-Community acquisitions of goods (ICA) and imports of services documented by a document other than an invoice. This decision helps standardize reporting practices, making compliance easier and reducing the likelihood of errors.
Implications for Taxpayers
The official guidance issued in April 2026 represents a pivotal shift in VAT reporting standards in Poland. Taxpayers must now be diligent in classifying their invoices and ensure they meet the new requirements of JPK_V7(3). To correctly mark a document as OFF, BFK, or DI, you must answer the following questions each time:
- Does the document have a KSeF number?
- Was it created during a system outage?
- Is the entry based on an invoice issued or received outside the KSeF system, or on a document other than an invoice?
Compliance Challenges
While these updates aim to simplify reporting and improve the efficiency of VAT collection, taxpayers may still face challenges. Businesses operating in multiple jurisdictions or those engaged in complex transaction types will need to invest additional time and resources to comply with these enhanced guidelines.
Commitment to Digital Transformation
Poland's commitment to fostering a robust digital VAT ecosystem is evident in these updates and the accompanying official guidance. By integrating JPK with KSeF, the Polish government is taking significant strides toward increasing transparency and reducing tax evasion.
Conclusion
The April 2026 official guidance from the Polish Ministry of Finance provides much-needed clarification on implementing JPK_V7(3) and aligning it with the KSeF system. Taxpayers must adapt to these changes promptly to ensure they correctly apply the new designations to various transaction types. As the Polish landscape continues to evolve towards digitalization in tax reporting, adherence to these guidelines will be crucial for ensuring compliance and optimizing tax processes in the years to come.
How Can KGT Support You?
KGT has created an SAP-integrated SAF-T add-on solution for Poland, featuring outbound and inbound functionalities to meet tax reporting requirements. This add-on includes a data extractor and a cockpit for generating periodic e-invoicing files in the legal format and controls before submission. When SAP DRC launched the Polish e-invoicing solution as part of its e-document offerings, KGT emerged as a leading consultancy firm for SAP DRC and tax services. Recognized as an SAP DRC partner for Polish e-invoicing services, KGT is one of SAP's recommended implementation partners for this solution. We provide comprehensive support, including installation, configuration, customization, and training, to help you maximize the long-term value of your SAP DRC investment.
KGT is an SAP partner for PE services and an SAP Build partner, and to become an SAP partner, strict due diligence requirements must be met, including having certified SAP consultants. You can find us at: https://partnerfinder.sap.com/profile/0001925409
