DI or BFK in JPK_VAT? The distinction according to Ministry of Finance answers

DI or BFK in JPK_VAT?

The absence of a KSeF number does not automatically mean DI. Nor should BFK be assigned to every cross-border transaction. What matters is the document categories and conditions listed by the Ministry of Finance in answers 8 and 9 of the KSeF FAQ.

This guide is limited to that distinction. It is neither a complete guide to completing JPK nor a guide to issuing invoices in offline modes.

DI — which documents does the Ministry list?

The Ministry begins its answer with evidence other than an invoice, but its detailed list also includes certain invoices. DI should therefore not be reduced to the phrase “a document that is not an invoice”. According to Ministry answer 8, the designation applies in particular to:

• Documents not covered by the OFF and BFK designations, such as an internal document or a summary sales document from cash registers.
• Invoices issued in offline24 mode — Article 106nda of the VAT Act — or during system unavailability — Article 106nh(1) — which do not have a number identifying the invoice in KSeF on the date the records are submitted.
• Entries concerning intra-Community acquisitions of goods (WNT) and imports of services documented by evidence other than an invoice, marked WEW in JPK.
• Entries concerning imports of goods accounted for under Article 33a of the VAT Act.
• Entries concerning supplies of goods for which the purchaser is liable for VAT under Article 17(1)(5) of the VAT Act.

OFF appears here solely as part of the distinction made in the source; this guide does not discuss its application.

When should DI be replaced with a KSeF number?

The Ministry identifies a specific situation in which the designation should change. It concerns an invoice that:

• was issued in offline24 mode or during system unavailability;
• was made available to the purchaser by means other than KSeF;
• was included in the records with the DI designation.

After obtaining the KSeF number, the taxpayer should correct the designation by entering that number for the invoice. This is not a general rule for changing every DI designation — it applies to the situation and conditions described above.

BFK — electronic and paper invoices issued outside KSeF

Ministry answer 9 concerns electronic and paper invoices issued without using KSeF. Below, we separate the items relating to sales records from the invoices for specified transactions listed in the same answer.

Items listed for sales records

The Ministry states that BFK must be used for invoices included in sales records that were:

• Issued during a total KSeF outage.
• Issued before 1 February 2026 and reported in JPK_VAT for a period from 1 February 2026 onwards. Both conditions must be retained — the issue date alone is not sufficient.
• Issued outside KSeF in February or March 2026 by taxpayers whose KSeF obligation begins on 1 April 2026.
• Issued outside KSeF in 2026 by taxpayers who are not required to issue invoices using KSeF.
• Issued outside KSeF and reported in connection with an adjustment for so-called bad debt relief. This specifies the designation, rather than explaining entitlement to the relief.

Invoices for transactions listed by the Ministry

The Ministry’s BFK list also includes invoices issued outside KSeF:

• for intra-Community acquisitions of goods (WNT) and imports of services;
• for imports of goods accounted for under Article 33a of the VAT Act;
• for supplies of goods for which the purchaser is liable for VAT under Article 17(1)(5) of the VAT Act.

This list should not be replaced with the shortcut “cross-border transaction = BFK”. In particular, for WNT and imports of services, the Ministry distinguishes between an invoice issued outside KSeF, listed under BFK, and evidence other than an invoice, marked WEW, listed under DI.

Optional organizational checklist

As a practical aid, you can prepare a short checklist:

• What type of evidence is it: an invoice or another document?
• In what mode and under what circumstances was the invoice issued?
• Does the invoice issued in offline24 mode or during system unavailability have a KSeF number on the date the records are submitted?
• Which specific item on the Ministry’s list matches the document, taking account of dates and the taxpayer’s status?
• Has the situation described by the Ministry requiring DI to be replaced with a KSeF number occurred?

This is an optional organizational recommendation, not an additional obligation arising from the FAQ or a guarantee that a particular tax settlement is correct.

Source: Ministry of Finance — KSeF frequently asked questions, answers 8 and 9.