The Finance Ministry has recently issued manuals for the National E-Invoicing System (KSeF) where it announced certain changes to the logical schemas of JPK_VAT files as of 1 Feb 2026, with the changes being different for:
- taxable persons on monthly reporting schedule (file JPK_V7M(3)), vs.
- taxable persons on quarterly reporting schedule (file JPK_V7K(3)).
The old implementing regulations concerning JPK_VAT will be amended to enact adjustments to JPK_VAT logical schemas reflecting the new reporting obligations.
As announced, as of 1 Feb 2026 businesses will have to ensure that their JPK_VAT files (V7M & V7K) contain the KSeF numbers assigned to the reported sales or purchase invoices. Where no KSeF numbers have been assigned, the invoices must be reported with appropriate codes. The KSeF number functionality is supposed to be implemented also in other JPK files, such as JPK_KR_PD.
It was already two years ago that the Finance Ministry was planning to have mandatory KSeF number references in JPK_VAT files but at that time the idea was limited to sales invoices only, with KSeF number disclosure for purchase invoices being voluntary.
The new requirement and the new JPK_VAT schemas mean additional revisions to companies’ accounting systems, which can pose quite a challenge, given the ongoing KSeF and JPK_CIT implementation projects. If your systems are not ready by 1 Feb 2026, your JPK_VAT filings may be rejected as incorrectly filled in, and this in turn may lead to financial penalties.
Feel free to contact our KSeF experts who will be happy to assist you in preparing for the new compliance duties based on your existing accounting systems and internal document management policies.
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