Starting with the February 2026 settlement, taxpayers are required to use the new JPK_V7M(3) and JPK_V7K(3) structures. The changes in reporting are directly related to the implementation of the National e-Invoice System (KSeF) and the next stage of VAT settlement digitisation. Although at first glance they may look like just another ‘system update’, in practice they represent significant substantive changes that affect the way transactions are recorded, the assessment of the correctness of settlements and the level of tax risk.

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New markings from 1 February for all taxpayers

The new JPK_V7(3) applies to all active VAT taxpayers, regardless of whether the entity already issues invoices in KSeF or whether this obligation will only apply to it from 1 April 2026 or 1 January 2027. One of the most common mistakes is to assume that the new markings come into force together with the KSeF obligations. This is not the case.

It is worth remembering that the new JPK_VAT structure:

  • does not eliminate existing markings such as TP, GTU, RO, FP, WEW, MK or VAT_RR – what is more, irregularities in the use of markings/their absence can be identified much more quickly by tax offices,
  • imposes new obligations in parallel to the existing ones – primarily in terms of additionally indicating the KSeF invoice number or one of the new tags explaining its absence (both on the sales and purchase side).

New markings – the source of the greatest doubts

In practice, the new document markings Nr KSeF, OFF, BFK and DI raise the most questions. Their use requires not only knowledge of the regulations, but also a good understanding of invoicing processes and document circulation within the organisation.

The most common concerns include:

  • what markings to display in the absence of a KSeF number,
  • differences between OFF and DI in the context of emergency modes ,
  • correct labelling of purchase invoices when the contractor sends the invoice via the existing channel in PDF or paper format and at the same time makes it available in KSeF,
  • what markings to use on invoices from foreign contractors.

Errors in this regard may result not only in the need for corrections, but also in the risk of financial penalties for irregularities in JPK_VAT, which, unlike KSeF sanctions, will apply from 1 February 2026.

The implementation of the new JPK_VAT scheme requires well-thought-out actions on the part of accounting and tax teams in cooperation with IT solution implementers. Due to the introduction of new markings, simply updating the financial and accounting system is not enough. It is crucial to properly understand the regulations and their practical application.

How can we assist you?

At CRIDO, we combine technical and tax expertise to provide comprehensive support to our clients. Our support may include, among other things:

  • mapping transactions/documents in order to assign new codes (NrKSeF, OFF, BFK, DI) – including practical workshops with the tax and accounting team,
  • verification of the correctness of transaction/document reporting – including the completeness of reporting in terms of other tags (e.g. TP, WEW, IMP, RO),
  • review and update internal policies, VAT procedures and document circulation,
  • ongoing advice and assistance with any queries arising during the initial settlements/implementation work,
  • support in preparing JPK_VAT in the required format, combining data from various sources, substantive and technical verification of the xml file – and, if necessary, we also handle the submission process.

The new JPK_VAT scheme is another step towards full VAT digitisation – but also a moment when it is worth ensuring that settlements are not only technically correct, but also tax-safe. It is also a good time to consider conducting a periodic VAT review and making any necessary adjustments before our data comes under scrutiny by the tax authorities. If you would like to discuss how to prepare your organisation for the new obligations, please contact the CRIDO team.

Worth reading:

[1] https://crido.pl/en/blog-taxes/vat-reporting-from-february-2026-new-symbols-old-fiscal-penal-code-sanctions/   

[2] https://crido.pl/en/blog-taxes/ksef-in-poland-on-the-horizon-continuity-of-invoicing-and-vat/

[3] https://crido.pl/en/blog-taxes/ksef-the-need-to-update-accounting-policy/