However, KSeF is mandatory in JPK_VAT declarations

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However, in the context of the JPK_VAT declaration, it will not be so different after it enters into force National e-Invoice System (KSeF), as announced by the Ministry of Finance (MF).

The Ministry had previously announced that it would not introduce changes to the KSeF and JPK_VAT declarations at the same time, because it is too much of a burden for taxpayers. However, the reality turned out to be different... yesterday, i.e. October 24, 2023, a draft Regulation was published, which from July 1, 2024 introduces, among others: obligation to provide the invoice number assigned by KSeF in the JPK_VAT declaration.

As we can read in the project justification:

"The purpose of the changes introduced is to adapt the regulation on JPK_VAT with the declaration to the changes introduced in the VAT Act regarding the implementation of the obligatory National e-Invoice System by the Act of June 16, 2023 amending the Act on tax on goods and services and certain other acts (Journal of Laws, item 1598), hereinafter referred to as the "KSeF Act", and updating the content of this legal act by:

  • adapting the regulation to changes in VAT refund deadlines (including shortening the basic refund deadline from 60 to 40 days, removing the additional 40-day refund deadline),
  • introduction to the regulation on JPK_VAT with the declaration of the invoice identification number in the National e-Invoice System,
  • marking invoices issued during the failure of the National e-Invoice System and during the period of unavailability of this system, also when issuing an invoice in KSeF was not possible for reasons attributable to the taxpayer.

Due to the above changes, a modification of the logical structure of JPK_VAT with declaration (the so-called JPK_VAT scheme with declaration) will be proposed, the current version of which will be published separately.

As soon as work on the Regulation enters a key phase, we will start working on adapting ours JPK_VAT application to the requirements defined in the final version of the regulation.

Source: Regulation amending the regulation on the detailed scope of data contained in tax returns and records in the field of tax on goods and services.