JPK VAT File Updates for Poland 2026 Electronic Invoicing Changes

Capture and report transaction classification codes on Payables and Receivables invoices when the KSeF number is unavailable or will be received later.

Keep KSeF numbers and classification codes synchronized across ERP records and Tax Registers.

Add new classification fields to the JPK_V7M(3) layout for taxable unrefunded packaging deposits.

On October 14, 2025, the Polish Ministry of Finance announced updates to the JPK Electronic Audit File VAT Register block, known as JPK_VAT. These updates align JPK_VAT reporting requirements with the mandatory KSeF e-invoicing regulations effective February 1, 2026.

The updates apply to both sales and purchase invoices, and include:

  • New indicators DI, BFK, and OFF for transactions processed outside the KSeF system.
  • New optional indicators P_360 and K_360 for tax on unrefunded beverage packaging deposits.
  • Updated totals for tags Deklaracja/PozycjeSzczegolowe/P_38 and Ewidencja/SprzedazCtrl/PodatekNalezny to include K_360 values.

The enhanced JPK_V7M(3) solution includes these changes:

  • New "Non-KSeF" indicator Global Descriptive Flexfields.
  • The new Non KSeF Category Global Descriptive Flexfield stores the non-KSeF category for non-standard invoice processing, values OFF, BFK, or DI, on both the transaction header in Receivables and the invoice header in Payables.
  • Users can update this field either manually by selecting a value from the list of values or using SOAP Web Services.
  • Tax amounts for unrefunded deposit collected for products in beverage packaging, P_360 and K_360.
  • The data model and report XML template are updated to report these values in the JPK_V7M(3) layout.

Here are the access updates:

  • You must enter GDF values for the purchase document type and KST classification for all active assets by January 1, 2026.
  • You must maintain depreciation method GDF values for all asset categories across accounting and tax asset books.

Retirements include:

  • Record the retirement reason during each retirement transaction starting January 1, 2026. Such values are used during JPK_ST report generation in 2027 to populate mandatory reporting fields.