On Wednesday (September 17, 2025), the Polish Ministry of Finance published draft versions of JPK_V7(3) logical structures. This marks another step in adapting VAT reporting to the requirements associated with the mandatory use of KSeF (National e-Invoicing System).
The past few months have undoubtedly been an intensive period for taxpayers. Following the completion of the legislative process concerning the mandatory use of e-invoices, efforts are underway to adapt KSeF to new technical requirements related to API 2.0. Moreover, the possibility of testing KSeF certificates will soon become available. In this dynamic period, the proposed changes to the JPK_V7 structure gain particular significance.
Adapting JPK_V7 to KSeF
As stated in the Ministry of Finance's announcement published on September 17, 2025, the new versions of the logical structures aim to adapt JPK_V7 file structure to KSeF requirements. Consequently, the new logical structures, i.e., JPK_V7M(3) and JPK_V7K(3), are to come into force on February 1, 2026. This date coincides with the effective date for the obligation to issue invoices in KSeF for taxpayers whose turnover in 2024 exceeded PLN 200 million (including tax).
The draft versions of the new logical structures also include fields intended to adapt JPK_V7 to regulations concerning the deposit-refund system.
New fields in JPK
The draft version of the JPK_V7(3) logical structure published on September 17 does not differ from the version proposed by the Ministry of Finance in June and subjected to public consultation. Thus, compared to the currently applicable JPK_V7(2), the adapted structure will contain new fields covering, among other things, the following types of data:
- KSeF identification number of the invoice (KSeF number),
- an indication that the invoice was issued in accordance with Article 106nf of the VAT Act, does not have an assigned KSeF number, and has not been sent to KSeF,
- an indication that a given item is an electronic or paper invoice,
- an indication that a given item constitutes evidence other than an invoice issued with use of KSeF.
According to the draft version of the JPK_V7(3) logical structure, it will be mandatory to complete one of the above-mentioned fields for each reported item. These new fields will appear in both sales and purchase evidence.
Furthermore, a new field concerning the amount of tax on unreturned deposits collected for beverage packaging products covered by the deposit-refund system will be introduced in both declaration part and sales records.
JPK_V7(3) vs. JPK Regulation
It is worth noting that the draft version of the JPK_V7(3) logical structure published by the Ministry of Finance is currently not consistent with the amendment to the so-called SAF-T Regulation (i.e., the Minister of Finance's regulation on the detailed scope of data contained in tax declarations and records for VAT). The SAF-T Regulation establishes the legal basis for reporting specific types of data within this logical structure, and its amendment, aimed at adapting to KSeF requirements, was announced in January 2024 (when the mandatory KSeF was still planned to come into effect on July 1, 2024). Currently, after the change of the effective date (to February 1, 2026), this amendment remains a pending legal act.
According to the aforementioned amendment to the SAF-T Regulation, the inclusion of data relating to the KSeF number of the invoice is to be mandatory only in sales records. This obligation will only become effective for taxpayers starting from August 1, 2026.
Conversely, in the draft version of the JPK_V7(3) logical structure, the Ministry of Finance indicated that it would be mandatory to complete KSeF-related fields in both sales and purchase records. Additionally, some of the data within the draft versions of the logical structures published by the Ministry of Finance are not listed in the content of the amended SAF-T regulation. At this moment, however, it cannot be definitively stated whether there will be another amendment to the mentioned regulation or further modifications within the proposed logical structures.
What does this mean for taxpayers?
The Ministry of Finance's publication of the draft versions of the JPK_V7(3) logical structures provides taxpayers with valuable information that will soon be essential for adapting systems and internal procedures to the new requirements related to VAT and KSeF reporting.
The actions of the Ministry of Finance suggest that work on implementing KSeF is nearing completion, while simultaneously picking up an extremely intensive pace in the final phase.
We would be pleased to discuss how this might impact your operations and work with you to find optimal solutions. Feel free to contact us.
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