Polen schlägt wichtige Änderungen an JPK_VAT vor

What Businesses Need to Know
The Polish Ministry of Finance has announced significant amendments to the regulation governing VAT returns and records (JPK_VAT). These changes, driven by the introduction of mandatory e-invoicing (KSeF) and the deposit – refund system (DRS), will require businesses to act quickly to update their internal IT systems and compliance procedures.

1. New Invoice Fields Linked to KSeF
Under the draft regulation, taxpayers must include the KSeF invoice identification number in JPK_VAT submissions. If the number is unavailable at the time of filing, businesses must use one of three mandatory codes:
• OFF: For invoices that should be issued via KSeF but were created outside the system due to a KSeF failure.
• BFK: For invoices issued outside KSeF (e.g., by non-established businesses or in paper form).
• DI: For internal documents or invoices issued offline during system outages. Once the official KSeF number is assigned, taxpayers must correct the JPK_V7 file.

2. Buyer’s Obligation to Include KSeF Number
The KSeF identification number will also need to appear in purchase records, meaning buyers must adapt their systems to capture and report this data accurately.

3. VAT Settlement for Un-returned Deposits
The Deposit Refund Scheme (DRS), effective from October 1, 2025, applies to beverage containers marked with the deposit – refund logo. Consumers pay a deposit at purchase, which is refunded upon return of the packaging. By December 31 each year, producers and importers must reconcile deposits collected versus refunded, reporting any difference in the first VAT return of the following year.
To accommodate this, JPK_VAT will include:
• A new field for the tax base and VAT due on un-returned deposits.
• Identification of the representing entity.
• A new document marker: “DEPOSIT SYSTEM.”

4. Shortened VAT Refund Deadline
With KSeF implementation, the standard VAT refund period will be reduced by one-third, from 60 days to 40 days, accelerating cash flow for compliant businesses.

Implementation Timeline
These changes will apply to:
– February 2026 filings for monthly VAT taxpayers.
– Q1 2026 filings for quarterly declarations.

What Businesses Should Do Now
The simultaneous roll-out of KSeF and new JPK_VAT requirements demands careful planning and system adaptation. Companies should:

– Review and update ERP and accounting systems.
– Train staff on new coding requirements.
– Establish processes for handling offline invoices and corrections.

Early preparation is critical to avoid compliance risks and operational disruptions.