As of 1 February 2026, new JPK_VAT file structures: JPK_V7M(3) and JPK_V7K(3) have come into force. The change applies to all VAT taxpayers required to submit JPK files, regardless of whether they already use the National e-Invoicing System (KSeF). In practice, this means that starting with the settlement for February 2026, all taxpayers must use the updated structures. Corrections for earlier periods should still be submitted according to the structure valid at the time, for example, corrections for January 2026 must be filed using the previous version.
The reporting obligation itself has not changed. Taxpayers settling VAT on a monthly basis continue to submit JPK_V7M files, while quarterly taxpayers submit JPK_V7K. Monthly filers report both the records and the declaration each month. In quarterly settlements, the first two months include only the records section, while the third month includes both the records and the declaration covering the entire quarter. The deadline remains unchanged and falls on the 25th day of the month following the reporting period.
The most significant update concerns the link between JPK and KSeF. From February 2026, the records section of the file must include the identification number assigned to an invoice in KSeF or an indication that such a number has not been assigned. In practice, this requires correct classification of documents. If an invoice already has a KSeF number, it must be reported in the JPK file. If an invoice was issued in contingency mode and does not yet have a KSeF number at the time of filing, the designation OFF should be used. Standard invoices issued outside KSeF, such as paper invoices or invoices issued to consumers, should be marked with BFK. Other documents, including fiscal cash register reports or internal documents, should be marked as DI. In some cases, documents may require more than one designation, for example DI and RO or DI and WEW. Not every situation requires a correction of the JPK file after a KSeF number is assigned, this depends on the type of document and the circumstances in which it was issued.
Changes also affect the VAT RR designation. Previously, it applied only to invoices documenting purchases from flat-rate farmers. From 2026, the designation also covers corrective invoices related to VAT RR transactions. In practice, this change will start to apply from April 2026, when the relevant provisions enter into force.
The new structures also reflect regulations related to the deposit return system. It is now possible to report VAT on unreturned deposits for returnable packaging, which is relevant for so-called representing entities. Two new fields have been introduced for this purpose – K_360 in the records section and P_360 in the declaration section. This solution will be particularly important for companies operating in the beverage and retail sectors.
The reporting rules for import of services have not fundamentally changed, but it is worth clarifying them. Output VAT should be reported in the appropriate fields (K_27 and K_28, or K_29 and K_30 for services from the EU), while input VAT should be reported in fields K_40 and K_41 or K_42 and K_43. Correct dates remain crucial, including the invoice issue date, service completion date, purchase date and the date the document was received. Import of services must be reported in the JPK file both as output VAT (at the moment the tax liability arises) and as input VAT (when the right to deduct arises).
In practice, the new requirements mainly mean more detailed reporting and greater emphasis on the accuracy of designations within the records. For many businesses, adapting accounting systems and internal procedures, particularly in relation to KSeF integration will be essential. With properly configured processes and up-to-date software, however, the transition can be handled smoothly, provided the new requirements are addressed in advance.