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KSeF Regulation – we are learning more and more
- Paweł Gorzelec
- 20 hours ago
- 2 min read
The National e-Invoicing System (KSeF) is approaching rapidly, accompanied by new executive regulations clarifying the practical application of mandatory e-invoicing in Poland. The Ministry of Finance continues to adapt VAT reporting rules to the new invoicing model.
One of the key legal acts is the Regulation of the Minister of Finance and Economy of 12 December 2025, amending the regulation on the detailed scope of data included in VAT returns and records. Its primary purpose is to align VAT records with the rules governing invoices issued via KSeF.
New markings in JPK_VAT
VAT taxpayers are required to apply specific transaction markings in the JPK_VAT file depending on the type of document.
The regulation introduces new codes applicable to documents other than invoices issued via KSeF or invoices issued outside the system:
“OFF” – an invoice issued during a KSeF outage that has not yet been assigned a KSeF number or submitted to the system as of the JPK filing date,
“BFK” – an electronic invoice or a paper invoice,
“DI” – a document other than an invoice issued via KSeF.
Failure to apply the correct markings may result in financial penalties, which is why this change is particularly important for both entrepreneurs and accounting offices.
Other changes in JPK_VAT
Another significant change is the obligation to include the KSeF invoice number in both sales and purchase records in JPK_VAT.
This requirement applies:
to all invoices issued via KSeF,
regardless of whether they were issued in standard mode or special modes (e.g. offline24),
based on the status as at the moment of submitting the JPK_VAT with the VAT return.
These rules will apply to reporting periods starting 1 February 2026.
Penalties – no automation, correction first
Importantly, penalties for incorrect JPK_VAT files will not be imposed automatically. Taxpayers will be given the opportunity to correct errors, and penalties may be imposed only if the taxpayer fails to submit a correction after being formally requested by the tax authority.
Each case will be assessed individually, reducing the risk of automatic sanctions for minor errors during the transition period.
Corrections of missing KSeF numbers
As a rule, there is no obligation to correct VAT records if the KSeF number had not been assigned at the time the JPK_VAT was submitted.
Exception: A correction of the sales record is required if invoices issued in offline24 mode receive a KSeF number after the JPK_VAT has already been filed. According to the Ministry, such cases should be rare.