Will KSeF replace JPK?

With the planned for 2024, the introduction of the National e-Invoicing System (KSeF) in Poland, the so-called structured invoice is to become the only accounting document in legal circulation. Meanwhile, entrepreneurs are obliged to provide the tax administration with Uniform Control Files (JPK). Will KSeF exempt them from this obligation?  

The obligation for businesses to issue JPKs was introduced in Poland in 2016-2018 based on Article 193a of the Tax Ordinance. Its purpose was to seal the tax system and standardize documents generated by various accounting systems. The National eInvoice System, which the Ministry of Finance is currently working on, is also supposed to perform the same tasks. Will the launch of the new digital invoice system be tantamount to the elimination of JPK? Let's start by comparing basic information about both types of documents.

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What is JPK?

Under the concept of the Single Audit File are accounting documents created by IT systems, concerning all business operations carried out by entrepreneurs over a specified period of time (monthly or quarterly). The JPK consists of logical structures specified in the Tax Ordinance for the electronic form of tax books and accounting evidence.

By the 25th of each month, entrepreneurs are required to send the tax administration the JPK_V7 file. It consists of a recording part (containing, among other things, data on purchases and sales) and a declarative part, in which VAT data must be included (among other things, the amount charged and due, the amount paid to the Tax Office or refunded).

In addition, the taxpayer is required to create and archive additional JPK files, the list of which includes: 
  

• JPK_FA - VAT invoices
• JPK_FA_RR - RR VAT invoices for agricultural crops 
• JPK_KR - books of accounts 
• JPK_WB - bank statements  
• JPK_MAG - data on warehouse management.
• JPK_EWP - records of income accounted for on a lump sum basis
• JPK_PKPIR - tax revenue and expense ledger
  
  

This data must be provided at the request of the tax office in the course of inspection or verification activities carried out by the tax authorities.  

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What is a structured invoice?

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Instead, the entry into force of the mandatory KSeF will mean that the single mandatory format for accounting documents will become the so-called structured invoice. According to the Law on Value Added Tax, it is an electronic document, issued using KSeF, saved in an established format and in a specified form. A structured invoice is built according to a scheme, allowing it to process and read, among other things, such information as:

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• sale date,
• invoice date,
• amount owed,
• contractor data.

Structured invoices are saved in xml format, conforming to the model logical structure published in the Central Repository of Electronic Document Templates (CRWDE) on the ePUAP platform. Each structured invoice is built from three types of fields:

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• Obligatory - filled out obligatorily, in accordance with the applicable law (e.g., NIP number in the field Entity1/Identification Data).
• Optional - to be filled in obligatorily only if the condition under the Act is met (e.g., P_11A in the Fa/FaFaFaFaFaFa element).
• optional - filled in voluntarily and not resulting from the provisions of the Value Added Tax Act (e.g., the PKWiU field in the Fa/Fa/Fa element). However, their completion may be required under the provisions of other laws.

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For more information on how to fill in the fields of a structured invoice and the format of the data entered into it, see the Ministry of Finance's information brochure. ‍

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Will KSeF abolish the obligation to issue JPK?

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Work on the legislation introducing KSeF is still underway and a clear answer to this question is still unknown. The introduction of mandatory electronic invoicing is aimed at simplifying the tax system and may lead to the elimination of the obligation for businesses to create JPK. This is because the invoices sent to KSeF will contain all the data provided to the tax authorities in the mandatory JPK_V7 file. The same will also apply to JPK_FA files submitted on demand. It remains an open question whether entrepreneurs will still have to create the remaining files from the JPK list.

KSeF - vademecum of an entrepreneur

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Want to know more? Our experts have created a vademecum for entrepreneurs preparing for the introduction of the new system, with answers to the most frequently asked questions about KSeF. You will learn from it, among other things, what a structured invoice looks like and what benefits it can bring to your company.        

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Download the entrepreneur's vademecum