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New markings in JPK_VAT – a quiet risk area after the implementation of KSeF

  • As of April 1, 2026, Polish local government units (LGUs) are fully mandated to use the National e-Invoicing System (KSeF), impacting not only invoice issuance but also VAT record-keeping.
  • New JPK_VAT structures (JPK_V7M(3) and JPK_V7K(3)) and specific document markings (KSeF number, “OFF,” “BFK,” and “DI”) became mandatory for all VAT taxpayers, including LGUs, starting with the February 2026 settlement, introducing complexities and common risk areas in reporting.
  • Implementing KSeF and these new JPK_VAT markings requires LGUs to adapt financial systems, review registration procedures, and verify data correctness, with a recommendation to correct past JPK_VAT files if the new designations were not included, to mitigate risks before tax authority verification.

Source Deloitte



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