JPK FA - new version of the structure from November 2019


The Ministry of Finance introduced the obligation to collect and submit data in the form of SAF-T structure. One of the mandatory templates for the collection and transfer of data to the Head of the National Tax Administration in electronic form corresponds to the logical structure provided for the SAF-T structure, i.e. containing information on issued sales invoices. From November 2019, a new version of this structure is to apply - JPK_FA. Let's see how it will differ from the current structure.

The new structure of JPK FA from November 2019

According to the SAF-T structure, information on all elements included in the invoice should be presented. Thus, the tax authority, when receiving an invoice in the SAF-T structure, should have all the data that the invoice has. Therefore, if changes in the field of invoices are implemented, it is also necessary to adapt the structure of JPK fa.

Despite the fact that the structure has already been published, tax authorities will be able to request it only from December 2, 2019!

From November 2019, a new structure will apply, marked as "Schemat_JPK_FA". The most important changes are:

In the Naglowek node

  • In the KodFormularza element the KodSystemowy attribute was changed to JPK_FA
  • The value 3 was entered in the VariantFormularza element
  • In the DataOd and DataDo elements the data type has been changed from etd: TData to tns: TData
  • The DefaultCurrencyCode item has been removed
  • In the KodUrzedu element, a description of the element with the following content was added: "Tax office code, appropriate for the taxpayer submitting JPK_FA"

In the Podmiot1 node

  • In the IdentyfikatorPodmiotu element, the "etd: TIdentyfikatorOsobyNiefizycznej" element type has been changed to "etd: TIdentyfikatorOsobyNiefizycznej1"
  • In the AdresPodmiotu element the type of the element "etd: TAdresPolski" was changed to "etd: TAdresPolski1"
  • The "choice" selection mechanism and a new AdresPodmiotu2 element with the "etd: TAdresZagraniczny" type has been added

In the Invoice node

  • Type attribute removed
  • In the description of the Invoice node, the sentence "Sales values ​​and tax amounts are filled in in currency,
  • in which the invoice was issued, except for the fields where the tax amounts have been converted in accordance with art. 31a in connection with Art. 106e paragraph. 11 of the Act "
  • The KodWaluty element has been added
  • In elements P_1 and P_6 the element types were changed from etd: TData to tns: TDataT
  • Descriptions of P_4B, P_5B, P_13_x, P_14_x and P_15 elements have been modified
  • Added elements: from P_14_1W to P_14_4W regarding invoices issued in foreign currencies (intended for tax amounts on the sum of the net sales value, converted in accordance with Article 31a in connection with Article 106e section 11 of the Act)
  • The P_18A element has been added - a marker of the split payment mechanism
  • Element P_22 has been added - marker for intra-community delivery of new means of transport
  • Changed P_106E_3 element from optional to required
  • The elements ZALZaplata and ZALPodatek have been removed
  • The element NrFaZapiczkowej for the numbers of previous advance invoices has been added

The StawkiPodatku node has been removed

In the FakturaWiersz node

  • Type attribute removed
  • The description of the FaturaWiersz node has been changed to "Detailed invoice items in the currency in which they were issued
  • invoice"
  • Optional Order and OrderCtrl nodes have been added for advance invoices

Therefore, the most important changes that have appeared in the new JPK_FA structure are related to the new regulations on VAT invoices in the scope of the split payment mechanism, which enter into force on November 1, 2019 under the VAT Act. However, the amendment was used to improve the structure by reporting VAT converted into PLN when reporting invoices in foreign currencies or indicating transactions regarding the sale of new means of transport in EU countries.

What is the purpose of introducing JPK FA?

From the outset, the invoice structure raises many questions from developers and taxpayers alike. The Ministry of Finance resigned from the part of SAF-T regarding purchase invoices. The purpose of introducing the SAF-T structure is to facilitate cross-checks. Moreover, it facilitates the possibility of checking tax documentation against source documents. The introduction of this structure certainly also streamlined the activities of the tax authorities. At the same time, it can be concluded that this is a step towards the creation of the Central Register of Invoices announced by the Ministry of Finance.

Purchase invoices outside JPK FA

At this point, it should be remembered that the Ministry of Finance has withdrawn from showing purchase invoices in JPK_FA and maintains this state. The withdrawal from reporting on purchase invoices was announced by the Ministry of Finance in response to question 18.

JPK FA and mandatory shipping

The JPK_FA structure is not sent monthly, contrary to the JPK_VAT structure. The structure of cpu fa sales invoices is submitted to the tax office at its request, i.e. in the event of an inspection or carrying out checking activities. Therefore, the monthly JPK_FA shipment is not the taxpayer's responsibility.

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How to download JPK FA in the system?

In order to download the JPK FA file (i.e. the JPK structure for sales invoices) from the system, go to the tab: REVENUE »SALE and then in the lower left corner of the table set the period for which the file is to be generated. In the next step, select the JPK FA option from the top menu bar. The file will be automatically downloaded to your computer.