Polish pre-filled e-VAT returns 2029

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Draft VAT Act amendments sets phased automatic preparation of JPK_VAT using KSeF, retail sales and other tax authority data

Poland has moved forward with plans to introduce pre-filled VAT returns, with the Ministry of Finance setting out a new e-VAT system that could begin rolling out from the fourth quarter of 2029.

Under draft project UD473, the Polish tax administration, KAS, would prepare taxpayers’ preliminary JPK_VAT records and VAT declarations, JPK_V7M and JPK_V7K, using transaction information already held in government systems.

The reform would represent the next major stage of Poland’s VAT digitalisation following the rollout of mandatory KSeF e-invoicing.

Rather than businesses assembling their VAT position entirely themselves and then reporting it to KAS, the tax authority would increasingly use transaction-level data already received to propose the VAT settlement.

However, taxpayers would remain responsible for checking, supplementing and accepting the proposed return.

See our Poland VAT guide for more details.

e-VAT rollout planned from Q4 2029

The Ministry plans to introduce e-VAT progressively for selected groups of taxpayers starting in Q4 2029.

Initially, the system is expected to cover no more than 5% of VAT taxpayers, approximately 100,000 entities.

Further data sources and taxpayer groups would then be added progressively.

The government’s longer-term ambition is much larger. Following full implementation of digital retail reporting, it estimates that up to 80% of VAT taxpayers could use e-VAT by 2035.

This means e-VAT should be viewed as a multi-year programme rather than a single 2029 implementation date.

KSeF becomes part of a wider VAT data ecosystem

KSeF mandatory e-invoicing provides KAS with transaction-level B2B invoice information.

But the proposed e-VAT regime goes further.

The government acknowledges that there is currently no single integrated system bringing together KSeF and other datasets held by KAS to produce a preliminary VAT settlement.

UD473 would establish the framework for doing this.

Data sources and system modules would be connected progressively. This means the first e-VAT returns available in 2029 are unlikely to contain all information necessary to complete a VAT return.

Taxpayers will initially have to add information that KAS cannot obtain from its connected systems.

Over time, the government intends to make the tax authority’s proposed VAT position increasingly complete.

Taxpayers must still validate and accept the return

Importantly, e-VAT will not remove taxpayer responsibility for the VAT return.

Businesses opting into the service through Poland’s e-Tax Office will receive a preliminary JPK_VAT settlement prepared by KAS.

They will then need to:

• review the information provided by KAS;
• add or correct information not available to the tax authority; and
• actively accept and submit the settlement.

There will be no automatic acceptance when the filing deadline expires.

The preliminary return itself therefore has no filing effect until the taxpayer approves it.

This creates an important new compliance requirement: businesses will need to reconcile the government’s version of their VAT position against their own ERP, accounting and transaction data before accepting it.

Retail sales data to feed e-VAT

A major addition to the proposals is the digitalisation of B2C retail reporting.

Poland says more than 44% of cash registers are still older devices that do not automatically transmit transaction information to KAS.

UD473 therefore proposes a new free National e-Registration Cash Register, KeKR, alongside the progressive withdrawal of old-style cash registers.

KeKR would enable businesses to issue fiscal receipts through a KAS application and automatically transmit retail transaction information.

It would also store fiscal receipts and prepare daily and monthly fiscal reports.

Combined with existing online cash registers, this should eventually provide KAS with much more complete B2C transaction data to feed into e-VAT.

E-receipts at the customer’s request

The reform also proposes changes to electronic receipts.

Paper receipts would remain the default, but customers could request an e-receipt, which the seller would then be required to provide.

Businesses using KeKR would still need the ability to print paper receipts. The proposal therefore includes a relief equal to 90% of the cost of a printer, capped at PLN 200 per device for up to two devices.

Existing old-style cash registers would progressively be replaced by online cash registers, virtual registers or KeKR.

Invoice deadlines could be shortened

The e-VAT project could also have consequences for Poland’s invoicing rules.

For KAS to prepare a VAT settlement before the taxpayer’s filing deadline, invoices need to reach the tax authority sufficiently quickly to be allocated to the correct VAT period.

The Ministry therefore says the reform will require shorter invoice issuance deadlines. This mirrors the 5-day purchase invoice e-reporting July 2030 demands from the EU.

It also links this change to the EU’s VAT in the Digital Age, ViDA, reforms, which are moving EU VAT towards faster digital invoice and transaction reporting.

The precise new Polish invoicing deadlines have not yet been set out in the project description.

From KSeF to government-calculated VAT

The significance of e-VAT goes beyond simplifying preparation of JPK_VAT.

Poland is progressively assembling the components required for the tax authority to calculate a taxpayer’s VAT position itself:

KSeF B2B e-invoices + digital B2C receipts + other KAS data → pre-filled JPK_VAT

The taxpayer’s role therefore starts to shift from preparing the VAT return towards validating the tax authority’s calculation.

That makes reconciliation increasingly important.

Differences can arise because of missing transactions, timing, invoice corrections, input VAT deductibility, partial exemption, special schemes and accounting adjustments that cannot necessarily be derived directly from an e-invoice or fiscal receipt.

Businesses will therefore need controls capable of reconciling the KAS-prepared VAT position back to their underlying ERP and transaction data before approving the return.

The Polish government currently plans to submit the UD473 project for Council of Ministers approval in Q4 2026.

Global trend to death of the VAT return

This reflects a broader trend across Europe. Governments are increasingly using e-invoicing and digital reporting data to simplify VAT compliance through pre-filled returns. Portugal has recently expanded pre-filled VAT returns, while several other EU tax authorities are exploring similar initiatives as real-time transaction data becomes available.

For businesses, this reinforces an important message. Mandatory e-invoicing is evolving beyond invoice exchange into a foundation for automated tax administration. As governments collect more transaction data in real time, the natural next step is to generate VAT returns automatically.

Yet automation does not eliminate the need for tax determination. A pre-filled return is only as accurate as the legislative logic sitting behind it. Governments may be able to populate fields automatically, but businesses remain responsible for ensuring that the underlying VAT treatment is correct.

For multinational businesses, this is another reminder that the future of VAT compliance lies in combining digital transaction reporting with robust tax determination. AI and automation can accelerate compliance, but legislative rules and business context remain essential to producing an accurate VAT return.