JPK_VDEK and Whitelist in Poland: news in VAT registers

With the early adoption of the SAF-T reporting system, Poland became a benchmark country for electronic tax compliance worldwide. In this post we will review the current state of the regulations and the most recent updates to take into account for the declaration of VAT records in this country.

Digital transformation in tax matters

Community regulations on billing matters have been developing since 2001. The existence of a large number of options among the internal regulations of the Member States of the European Union means that, in terms of billing, it has been difficult to achieve the degree of harmonization or approximation wanted.

This divergence between the laws of the different Member States has been tried to solve through different rules. With this objective, as a result of Directive 2014/55/EU on electronic invoicing in public procurement, since January 1st 2013 equailty of treatment between paper invoices and electronic invoices has been guaranteed in all member states, forcing invoice recipients to accept and process electronic invoices.

Electronic invoicing compliance in Poland

Following the European guideline, Poland was one of the pioneer countries in the adoption of electronic tax reporting solutions. It started the journey in January 2016, forcing large companies registered for VAT purposes in Poland to submit a monthly VAT return electronically, a requirement that was extended in 2018 to all companies operating in Poland.

The solution implemented in Poland is called JPK (Jednolity Plik Kontrolny), and it is a type of file base don the standard XML protocol “Standard Audit File for Tax”, kinown as SAF-T, which was developed by the Organization for the Cooperation and Development Economic (OECD) for the electronic filing of tax information.

All companies are required to periodically issue a single file called JPK_VAT, through which VAT records are electronically declared..

SAFT-T Standard

Originally, the reporting solution defined in Poland consisted of a series of files based on the SAF-T protocol. However, with the aim of optimizing the reporting process, eliminating duplications in tax infprmation, the Polish Ministry of Finance published an update of the JPK file structure, the adoption of which by companies is mandatory since October 2020.

In this new version, the documents are unified in a single SAF-T file, replacing the VAT-7, VAT-7K, VAT-27, VAT-ZT, VAT-ZZ and VAT-ZD..

This update involved the inclusion of new fields in the JPK_VAT file, in order to include in this document the VAT refund information that was previously reported through different files. The final versión of the JPK file consists of 2 componentes:

  • VAT Registration: it includes the detail at the invoice leve lof all sales and purchases that are included in the VAT declaration.
  • VAT Refund (JPK_VDEK): using the VAT-7M model for those taxpayers who pay the tax monthly, and the VAT-7K model for quarterly taxpayers.

At Brait, we have experience implementing the SAP addon for the SAP ERP developed by SNI that allows integration between the SAP system and the official Polish government platform. This solution allows the extraction of data from the SAP system and its automatic reporting.


Another news published on tax matters in Poland is the creation of the “Biala Lista”, also called the Whitelist in English. It is an electronic database containing VAT taxpayers registered in Poland, and was introduced by the Polish Ministry of the Finance in September 2019 with the main objective of eliminating tax fraud.

This database contains companies’ legal information, including the tax identification, the corporate name, the date of registration and the bank details published in the tax agency.

Through this database, it is posible to verify the fiscal status registered entities, this being very useful when checking posible VAT deductions and having a high degree of control over the security transactions.

There is no explicit obligation for taxpayers to verify the bank accounts of their suppliers in the database. However, for transactions between companies (B2B) that exceed 15,000 zlotys (VAT included), the rule imposes the restriction of issuing bank transfers only to those bank accounts published in the database.

Failure to comply with the previous rule, entails the risk of losing the right to deduct VAT from the invoice.

To comply with this restriction, it is necessary that the bank details of the company are verified on the day the request for the bank transaction is executed. Verification can be carried out directly in the official website of the database.

From the finance ministry’s own website, it is posible to access the official API that allows massive queries to the database. Through this API, the tool developed by SIN for the SAP ERP allows us to do a mass check of the Whitelist immediately. In addition, through this solution, it is possible to block or unblock the provider for payment by master data, thus affecting all its open ítems that can be processed when executing the payment program.

If you are looking for a tool to address Polish legal requirements, or if you want more information about these or other alternatives, do not hesitate to contact us. We will be delighted to help you.  

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