From 1 February 2026, the new JPK_V7M(3) and JPK_V7K(3) structures will come into force. The key change is that without KSeF numbers or appropriate tags for invoices (both sales and purchase), the file will be automatically rejected at the technical validation stage. For entrepreneurs, this means that they must urgently adapt their financial and accounting systems to the new requirements.

 

What exactly is changing in the structure of JPK_V7(3)?

The most important change concerns the new obligation to additionally mark each invoice in the records. From 1 February 2026, taxpayers must provide the KSeF number in their sales and purchase records if the invoice was issued in the National e-Invoice System. If there is no KSeF number, one of three new tags must be used: OFF, BFK or DI.

This is a significant change compared to earlier announcements, according to which the obligation to indicate KSeF numbers was to apply only to sales (providing KSeF numbers on the purchase side was to be entirely optional). From 1 February 2026, providing the KSeF number or the appropriate tag will become mandatory in both sales and purchase records. Failure to provide this data will result in the JPK_V7 file being rejected at the technical validation stage.
 

New tags – rules of use

OFF – KSeF failure mode

The OFF tag is used for invoices issued during a confirmed failure of the National e-Invoice System. This refers to situations specified in Article 106nf(1) of the VAT Act, when, on the date of submission of the JPK_VAT, the invoice does not have a KSeF number and has not been sent to the system. It should be remembered that after the failure has ceased, the taxpayer has 7 days to send the invoice to KSeF.

In practice, this means that if you issue a paper or other form of invoice during a KSeF failure, you must mark it as OFF in JPK_V7. This is an exceptional situation, related exclusively to unforeseen technical problems on the part of the Ministry of Finance.
 

BFK – Invoices outside KSeF

The BFK designation applies to electronic invoices and paper invoices that have been issued without using the National e-Invoice System. We use them in cases where the taxpayer benefits from exemptions from the obligation to issue invoices in KSeF provided for in the Act.

Typical cases of BFK use include invoices from cash registers (until the end of 2026), invoices for consumers in B2C relations issued outside KSeF, and invoices for financial services benefiting from the KSeF exemption. This tag allows for the correct settlement of transactions which, for various legal reasons, cannot or do not have to be processed by the KSeF system.
 

DI – Other Documents

The DI designation refers to all other documents that are not invoices and do not qualify as OFF or BFK. We use it primarily for non-invoice documents, such as customs documents, internal documents or other accounting evidence.

It is particularly important to use DI for invoices issued offline24 as specified in Article 106nda of the VAT Act. When a taxpayer issues an invoice in this mode and does not yet have a KSeF number on the date of submitting JPK_V7, or the invoice has not been sent to the system, they must mark it as DI. After obtaining the KSeF number, the taxpayer is required to submit a correction to JPK_V7 and fill in the correct invoice identification number in KSeF.

Documents marked as DI also include, among others, daily reports from cash registers (which we additionally mark as RO), internal documents (WEW), customs documents (SAD) and others.
 

New item in JPK_V7(3) – deposits for returnable packaging

From 1 February 2026, new fields will also be introduced in JPK_V7(3) concerning the settlement of VAT on unredeemed deposits for products in beverage packaging covered by the deposit system. These changes result from the Act of 21 November 2024 amending the Act on packaging and packaging waste management and certain other acts.

Those introducing products in beverage packaging must now determine the difference between the value of deposits collected and returned in a given year. This difference must be reported in JPK_VAT for the first settlement period of the year following the year for which the difference was determined. For taxpayers who settle on a monthly basis, this will be the JPK_VAT for February 2026, while for quarterly taxpayers, it will be the JPK_VAT for the first quarter of 2026, with this data already having to be reported in the records for February.
 

Readiness of financial and accounting systems

A key element of preparation for the new requirements is to verify the readiness of the financial and accounting system. First and foremost, the system must enable automatic retrieval of the KSeF number and metadata for the invoice and save them in both the sales and purchase records. This number should then be correctly exported to JPK_V7.

In the case of OFF, BFK and DI tags, the system must allow the user to enter them manually with appropriate validation of correctness. It is not permissible for a user to mark a single invoice with several mutually exclusive tags at the same time. The system should also support combinations of tags, such as DI with RO, or FP with KSeF/OFF/BFK number.

If a company is subject to a deposit system for returnable packaging, its financial and accounting system must allow it to show the tax base and tax on the unreturned deposit and automatically reduce the total tax due by this amount.

Pre-shipment validation is equally important. The system should block the possibility of sending JPK_V7 if any invoice does not have a KSeF number or the appropriate tag. The user must receive clear information about the missing data. In addition, the system should test the generated JPK_V7 file for compliance with the new XML schema before it is sent to the Ministry of Finance.
 

Common errors and how to avoid them

The first common error is the lack of a KSeF number for an invoice issued in the National e-Invoice System. It happens that the invoice was created correctly in KSeF, but the ERP system did not automatically download the identification number or did not save it in the records. The solution is to ensure automatic integration between the financial and accounting system and KSeF so that the number is downloaded and saved without the need for manual intervention.

Another common error is the incorrect use of the DI tag instead of BFK. Accountants may mistakenly mark paper invoices issued to B2C customers as DI, when they should be marked as BFK. It should be remembered that BFK applies to electronic and paper invoices issued outside KSeF, while DI refers to documents other than invoices or offline invoices without a KSeF number.

The third problem concerns invoices issued offline. Taxpayers sometimes mark such invoices as DI in JPK_V7, but after obtaining a KSeF number, they may fail to fulfil their obligation to submit a correction. Meanwhile, the regulations clearly require that after receiving the invoice identification number in KSeF, the taxpayer corrects the records and enters the correct number instead of the DI designation.

The fourth error is to mark the cash register report only with the RO symbol (as has been the case so far), without the accompanying DI. In the JPK_V7 structure, the RO tag can only appear in conjunction with DI.
 

VAT registration in Poland

It should be remembered that the JPK_V7 scheme does not distinguish whether a given entity has its registered office / fixed establishment in Poland or whether it has a "normal" VAT registration. Thus, even if a foreign entrepreneur registered for VAT purposes in Poland does not have a registered office or fixed establishment here, it will be necessary for them to provide their KSeF number or the appropriate tag (both on the sales and purchase side). From the sales perspective, the option to provide the KSeF number results from the possibility (despite the lack of obligation) to issue an invoice in KSeF, while on the purchase side it may be an additional administrative burden, as such an entity will have to identify whether the invoice has a KSeF number and, if not, what tag should be applied to it.
 

Action plan

Preparing for the changes requires systematic action. Contact your software provider and obtain clear information about the system's readiness to handle the new JPK_V7(3) requirements. It is necessary to check whether the system supports KSeF numbers in sales and purchase records, OFF, BFK, DI tags and combinations of tags. If the company is covered by a deposit system, it is necessary to verify the possibility of settling tax on unreturned deposits. The supplier should be required to provide a specific implementation schedule for the update.

The second step is testing. Tests should be carried out to generate JPK_V7 files with new data and check their validation. It is worth testing all possible scenarios: invoices in KSeF, invoices in failure mode (OFF), invoices outside KSeF (BFK), other documents (DI), offline24 invoices and invoices for receipts in various configurations.

The third step is comprehensive team training. Accountants must thoroughly understand the rules for marking individual documents and know when to use OFF, BFK or DI. Those issuing invoices should learn about the offline24 mode and the rules for its use. The sales team, on the other hand, should know how to properly handle customer requests for receipts.

The fourth step is the final implementation, which must be completed by 1 February 2026 at the latest. All accounting procedures, instructions and document flows must be updated. The FK system must be updated to the latest version supporting JPK_V7(3). It is also worth preparing a contingency plan in case of problems with sending JPK_VAT or unforeseen technical difficulties.
 

Last chance for preparation

The financial and accounting system must be fully ready to handle the new requirements so that the return for February 2026 can be submitted without any problems on 25 March. Postponing testing until the last minute may result in the blocking of returns and problems with VAT settlement. Training the team is just as important as updating the software, as it is the accountants who will make day-to-day decisions about the correct marking of documents.

There are less than three months left until 1 February 2026. This is the last chance to start preparing the system for the new reality and avoid problems with VAT settlement.

Given that the Ministry of Finance has not yet published the final version of the scheme, it is necessary to monitor announcements on an ongoing basis and adapt systems to any changes.

It is also worth preparing a contingency plan in case the system provider fails to deliver the update on time or unforeseen technical problems arise. If you need our support in this regard, please contact us.