JPK_MAG(2) from 2027 – new requirements for electronic warehouse records

Who may be required to submit JPK_MAG (SAF-T_warehouse)?

Taxpayers who maintain inventory records electronically are required to submit the JPK_MAG structure at the request of the tax authorities. The file may be requested in the course of tax proceedings, verification activities, a tax audit or a customs and tax audit. As a rule, the deadline for submitting the file is three days from receipt of the request.

Failure to submit JPK_MAG within the required deadline may entail the risk of liability under fiscal penal regulations.

Key changes to the JPK_MAG(2) structure

Compared with the current JPK_MAG(1) structure, the new version introduces changes in three key areas. These are important both in terms of the scope of data stored in warehouse management systems and the way this data is reported to the tax authorities.

• Warehouse documents will include invoice numbers assigned by the National e-Invoicing System (KSeF).
• The structure will be adapted to support all methods of maintaining subsidiary ledgers for inventory transactions provided for under the Accounting Act.
• The catalogue of documents will be expanded to include sections for inventory counts and internal receipts (PW), while inter-warehouse transfers will be separated into dedicated goods receipt and goods issue sections.

The scope of changes compared with the current structure is presented below:

What does the introduction of JPK_MAG(2) mean in practice?

Implementing the new structure may prove complex from both a technological and business perspective. Preparations should therefore begin well in advance and cover not only system configuration, but also the quality, completeness and consistency of source data.

The first step should be to check with the software provider responsible for the inventory management system whether the system will support the timely generation of a correct and complete JPK_MAG(2) file in the required format. The review should also cover the availability of all data fields required by the new structure and the possibility of carrying out tests before the new requirements take effect.

Detailed information

Detailed information on JPK_MAG(2) has been published by the Ministry of Finance in an information brochure available here. Given the planned effective date of the new structure, taxpayers maintaining electronic inventory records should already assess their systems’ readiness to generate the new version of the JPK file and introduce any necessary modifications.