The Ministry of Finance explains the rules for using the new tags in JPK_VAT
From 1 February 2026, all active VAT taxpayers must submit their JPK_VAT returns using the new file formats: JPK_V7M(3) and JPK_V7K(3). The templates were published by the Ministry of Finance in the Central Repository of Electronic Document Templates (CRWDE) in December 2025 and have been the only mandatory format for VAT reporting since February 2026.
From the taxpayers’ perspective, the most significant change is not the technical aspect itself, but the introduction of a new set of tags used when an invoice does not have a KSeF number on the date of submitting the JPK_VAT. It is precisely these markers - their scope and correct application - that have raised the most questions among taxpayers in recent months.
In the sales and purchase records, each invoice must be reported either with a KSeF number (NrKSeF) or - if such a number has not been assigned as of the JPK_VAT submission date - with one of three markers: OFF (an invoice issued during a KSeF system outage), BFK (an invoice issued outside KSeF, including, for example, a paper or electronic invoice), or DI (a document other than an invoice, e.g. an internal document). The purpose of the new tags is to clearly indicate the status of the document at the time of reporting (more details on the new markers can be found on the blog[1]).
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Problematic BFK and DI Markers
The BFK and DI markers raised the greatest doubts among taxpayers in the context of reporting transactions with foreign entities, such as intra-Community acquisitions of goods (ICA) or the import of services.
As a rule, businesses receive invoices from their counterparties and record them accordingly in the sales and purchase records. Where such a document is not available, ICA and import of services transactions are reported on the basis of an internal document (marked with the ‘WEW’ marker). The situation was further complicated by guidance from the National Tax Information (Krajowa Informacja Skarbowa, KIS), which in individual responses to taxpayers’ inquiries indicated that the DI tag should be applied to invoices received from foreign counterparties, whereas an interpretation of the regulations supported the applicability of the BFK tag.
The doubts were ultimately resolved by the Ministry of Finance, which decided to publish guidelines entitled ‘JPK_VAT with return– application in the records section of tags in the field “Invoice data or markers relating to the occurrence of invoices in the National e‑Invoicing System” – case summary’[2]. The position of the Ministry of Finance can also be found in the EUREKA database[3].
Ministry of Finance Guidelines::
- present the rules for using tags in a clear tabular format – separately for sales and purchase records,
- confirm that tags are required in all cases where an invoice does not have a KSeF number as of the JPK_VAT submission date,
- They explain that invoices from foreign counterparties relating to intra-Community acquisitions of goods or the import of services should be marked with the BFK tag. The DI tag should be indicated only where entries in the records are made on the basis of a document other than an invoice, e.g. an internal document.
***
At CRIDO, we have consistently presented a uniform position on the application of the BFK and DI tags and, even before the Ministry of Finance published its guidelines, we recommended that our clients apply the BFK tag to invoices relating to intra-Community acquisitions of goods and the import of services, based on our interpretation of the regulations.
Nevertheless, for many taxpayers the publication of the explanations may have come too late, as VAT records for February 2026 may have already been submitted. In such cases, businesses face practical dilemmas and questions as to whether a correction of the JPK_VAT is required and, if so, to what extent. It should also be borne in mind that errors in JPK_VAT records may result in the tax authority imposing a financial penalty of PLN 500 for each identified irregularity.
If these dilemmas also concern you, we encourage you to contact us directly — we will be happy to assist.
[1] Further reading:
https://crido.pl/en/blog-taxes/jpk_v73-new-schema-already-from-reporting-for-february-2026/
[2] https://ksef.podatki.gov.pl/media/vumdgkoe/jpk_vat-z-deklaracja-stosowanie-znacznikow.pdf
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