JPK FA structure - everything you need to know


From July 1, 2018, every entrepreneur (micro, small, medium and large) is required to submit other JPK structures at the request of the tax authorities. They include, among others JPK FA, JPK PKPIR, JPK EWP, JPK KR, JPK WB and JPK MAG. At the same time, it should be borne in mind that not all structures will apply to every entrepreneur. Among the listed structures of the Uniform Control Files, we will focus in the article below on what the SAF-T structure looks like and what requirements it should meet.

What is JPK FA?

The JPK FA file includes issued sales invoices. Interestingly, originally the Ministry of Finance assumed that SAF-T will apply to both sales invoices and cost invoices. However, this idea was eventually abandoned and SAF-T now includes only income invoices in its structure. It is worth mentioning that the SAF-T structure contains the most fields from all other JPK structures, because as many as 92 fields, 43 of which are mandatory.

SAF-T, the structure of sales invoices applies to entrepreneurs who keep accounting records in electronic form. This was confirmed by Director Przemysław Krawczyk himself in the interview "The Ministry will make it easier for taxpayers to prepare JPK FA" of May 29, 2018, in response to the question Will the taxpayer who has scans of paper invoices be subject to SAF upon request? He directly indicated in it that the taxpayer - if he keeps books in electronic form, and only archives paper invoices in the form of scans, he will have to generate SAF-T at the request of the tax office. If the books are not kept in electronic form, SAF-T will not cover them on request. After all, an invoice in the form of a logical structure is neither a scan nor a PDF that cannot be edited. Only data that can be processed are such invoices.

Therefore, if the entrepreneur does not keep online accounting and issues paper invoices, then he is not obliged to submit SAF-T.

JPK FA structure - what does it contain?

The elements of individual sales invoices contained in the JPK FA file include, among others, the following data to be included:

  • date of issue,
  • consecutive invoice number, given within one or more series, which uniquely identifies the invoice,
  • name and surname or name of the buyer of goods or services,
  • buyer address,
  • name and surname or name of the seller of goods or services,
  • seller's address,
  • the number by which the taxpayer is identified for tax purposes,
  • the number by which the buyer of goods or services is identified for the tax or value added tax under which he received the goods or services,
  • the date of making or completing the delivery of goods or performance of the service or the date of receipt of payment,
  • sum of the net sales value with the basic, reduced or 0% rate - in the case of active VAT payers,
  • sum of the value of exempt sales - in the case of VAT exempt taxpayers,
  • the amount of tax on the sum of the net sales value with the basic or reduced rate in the case of active VAT payers,
  • total amount due,
  • P_16 - in the case of using the VAT cash method, enter the phrase TRUE in this field,
  • P_17 - in case of self-billing, enter TRUE in this field,
  • P_18 - in the case of using reverse charge, the phrase TRUE should be entered in this field.

The above information contained in JPK FA shows that the file contains all the obligatory elements of the invoice indicated in the VAT Act, namely art. 106e paragraph. 1. In the SAF-T structure, the following basic information is presented in the "Invoice Type" item in the form of a designation classifying the type of invoice:
- VAT - an ordinary VAT invoice, in accordance with the Act,
- CORRECTION - correcting invoice,
- ZAL - advance invoice or advance-final invoice,
- POZ - other types of invoices, e.g. invoice for a receipt.

JPK FA - sales invoice in a foreign currency

In the case of issuing sales invoices in a foreign currency, the Ministry of Finance indicated that a separate JPK FA should be generated with an indication of the currency to which the generated file relates. Then, in the "Default Currency Code" field, we enter the appropriate code of the currency in which JPK FA is generated, eg EUR, GBP, USD. By specifying the currency in this item, we disable the option to include data in other currencies. Only invoices assigned for one currency should be sent to the JPK FA file. When having sales invoices with different currencies, separate JPK FA files should be generated for each currency separately. It is equivalent that the amounts indicated in these invoices are not converted into the Polish currency.

VAT exemption and JPK_FA

Taxpayers exempt from VAT on the basis of the objective or subjective exemption are additionally required in the JPK_FA structure in the header P_19 to enter the value "true" and - indicate in item P_19C a provision of the act or an act issued on the basis of the act, on the basis of which the taxpayer applies tax exemption, e.g. art. 43 (1) of the VAT Act - exemption due to the subject of business activity.

Requirements for the preparation of the Uniform Control File for sales invoices

Due to the fact that the SAF-T structure including sales invoices should be submitted at the request of tax authorities, the legislator provided for the requirements regarding the data carrier on which this file should be provided. Pursuant to § 3 of the Regulation on the method of sending tax books by electronic means of communication and technical requirements for IT data carriers on which these books can be saved and transferred, the carriers must be:
  1. marked in a manner allowing for unequivocal identification of the carrier;
  2. adapted to be transferred between commonly available reading devices;
  3. suitable for storage at 18–22 ° C and 40–50% relative humidity.

It is worth emphasizing that the saved JPK files should ensure the possibility of faithful reading of data in devices produced by various manufacturers, appropriate for a given type of carrier (they may be, among others, DVDs, CDs, external drives or USB flash drives). On the government website of the Ministry of Finance,, in the information on the single control file upon request, it was indicated that SAF-T can be submitted electronically via the application:
- JPK 2.0 client,
- e-micro-company
by authorizing the shipment with your own qualified signature or with a trusted profile. However, only entrepreneurs running a sole proprietorship may use the option to send this file electronically.

Generating JPK_FA in the system

In the system, it is possible to easily and conveniently generate JPK FA with the scheme: REVENUE »SALE, where first select the period for which the file is to be generated and then select the option DOWNLOAD JPK FA.

Then the JPK FA structure in XML format will be downloaded to the computer disk.