Starting from 1 February 2026, a new, third version of the VAT evidence reported as a part of the SAF-T for VAT (JPK_VAT structure) will come into force. Along with it, a new set of data and document codes will be introduced for all taxpayers disposing Polish VAT number. Unlike the postponed sanctions for failing to issue invoices via KSeF, the sanctions related specifically to reporting – includeing irregularities in completing the JPK_VAT – will remain in force.

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These changes stem from the Regulation of the Minister of Finance and Economy dated 12 December 2025 [1]. The new markings were introduced at the last minute, and ever since they were proposed, they have sparked numerous discussions that are now turning into practical challenges for implementers and tax accounting teams.

New data in the JPK_VAT

In the new schema – both in sales and purchase records – every VAT taxpayer will be required to include either the KSeF invoice identification Number (“Numer KSeF”) or indicate the reason for its absence by selecting one of the codes: “OFF”, “BFK”, or “DI”. Only one of these options should be shown, corresponding to the status of the document at the time of reporting, i.e. on the day the records are submitted.

The already existing codes will continue to apply, such as:

  • “RO”, “WEW”, “FP”, “GTU” on the sales side,
  • “VAT_RR”, “WEW”, “MK” on the purchase side,
  • “TP” for transactions on the output VAT side.

Thus, for example, when deducting VAT on imported goods based on a customs document, the taxpayer will need to apply both the “IMP” code (as before) and the “DI” code in the new field.

The JPK_VAT corrections

It’s important to remember that different correction rules apply to codes “DI” and “OFF”. Documents marked “OFF” do not require a later correction once the KSeF Number is assigned – this is based on guidelines published by the Ministry of Finance [2].

The situation is different for documents marked “DI”, which also includes invoices issued in offline24 mode (Art. 106nda of the VAT Act) or during KSeF unavailability (Art. 106nh(1) of the VAT Act) if they do not yet have a KSeF Number at the time of submitting the JPK_VAT. In such cases, the taxpayer must correct the records once the KSeF Number is assigned, replacing the “DI” code with the correct KSeF Number.

New challenges – how to implement the new requirements effectively?

Although there are only (or as some may say: as many as!) four new codes to choose from, practical experience shows that they raise numerous questions. These lead to dilemmas regarding how to efficiently structure the process of assigning the new markings in the financial accounting system or automate it. Substantive questions arise especially when considering invoices received outside of KSeF, e.g. from foreign suppliers documenting intra EU acquisitions of goods or import of services – and these are not clearly addressed in the regulations, which describe the new obligations only briefly.

When implementing the new requirements, it is worth ensuring that you:

  1. Identify and review all invoicing / documentation processes in the company and establish a procedure for assigning the codes – consider which types of documents / transactions should correctly receive “OFF”, “BFK” or “DI”.
  2. Provide training for the tax and accounting team (workshops) – safe implementation requires understanding the differences between the codes and setting a clear process for determining when corrections may be necessary.
  3. Verify system integration with KSeF - ensure that the system correctly reads the status of documents sent to KSeF, retrieves KSeF Numbers, and allows for corrections of records.
  4. Prepare an implementation checklist or update existing instructions/procedures with information about the new codes – this should clearly describe the rules adopted and provide effective support for daily reporting.

If you would like to discuss any dilemmas arising in this area, our team is here to help.

[1] https://dziennikustaw.gov.pl/D2025000180001.pdf

[2] https://www.podatki.gov.pl/media/wgbkrejs/broszura-jpk_vat-z-deklaracj%C4%85-od-1-lutego-2026-r.pdf