JPK_MAG(2) and SAP: 4 Areas to Consider Before 2027

Starting January 1, 2027, the new JPK_MAG(2) structure will take effect. It applies to all taxpayers who maintain electronic inventory records, regardless of whether they use a comprehensive ERP system or keep records in spreadsheets. Data for periods up to December 31, 2026, will continue to be reported in accordance with the current version of the structure. There is no obligation to convert historical data to the new format.

At first glance, JPK_MAG(2) may seem like just another technical update. In practice, however, the changes are much more extensive. The new structure expands the scope of reported data, introduces new sections, and links inventory records even more closely to invoicing processes in KSeF.

For organizations using SAP, this means they must consider not only the process of generating the JPK_MAG(2) file itself, but also the quality, completeness, and consistency of the source data. It is advisable to begin this analysis well in advance.

What is JPK_MAG(2) and who does it apply to?

JPK_MAG is one of the structures included in the Standard Audit File (JPK) that reports inventory turnover. The new version, designated as JPK_MAG(2), will apply to periods beginning on or after January 1, 2027.

This requirement applies to taxpayers who maintain inventory records in electronic form. If records are maintained exclusively in paper form, there is no obligation to submit JPK_MAG.

The file is not submitted on a regular basis. It is submitted only at the request of the tax authority, including during a tax audit, verification proceedings, or a customs and tax audit.

Why is JPK_MAG(2) more than just a new XML structure?

The most important change does not concern the file format itself.

The Ministry of Finance has expanded the structure in such a way that it is now possible to link inventory data much more precisely to sales and purchasing processes. Of particular importance is the inclusion of the KSeF number in selected inventory documents.

In practice, this means a greater emphasis on data consistency across inventory, logistics, accounting, and invoicing. Organizations will need to ensure that information generated in various processes can be correctly linked and reported.

What to Keep in Mind When Preparing SAP for JPK_MAG(2)

1. Linking Warehouse Documents to a KSeF Number

One of the most important changes in JPK_MAG(2) is the ability to report a KSeF number for selected warehouse documents.

From an SAP perspective, this is not always obvious. Material documents, logistics invoices, and financial documents function as separate system objects. Therefore, it is advisable to verify now whether existing data links will allow for the correct reporting of the KSeF number in the required locations within the structure.

2. Reporting Inter-Warehouse Transfers

The new structure also highlights the method of reporting movements between warehouses. In practice, this means ensuring data consistency between the issuing warehouse and the receiving warehouse.

For organizations with a decentralized warehouse management system, it is advisable to analyze in advance whether the current recording method will allow for the proper preparation of data for reporting.

3. New PW and INW Sections

JPK_MAG(2) expands the structure to include sections for internal receipts (PW) and inventory (INW).

Now is a good time to verify whether all required information is currently being collected in the system and whether its quality will allow for accurate reporting. In the case of inventory, data related to the inventory count process is of particular importance.

4. Support for Various Inventory Accounting Methods

The previous JPK_MAG structure supported only the quantity-value method. JPK_MAG(2) expands this scope to include all four inventory accounting methods provided for in the Accounting Act.

For some organizations, this may mean the need to review their record-keeping practices and assess how the chosen method affects the reporting process.

How much time does a company have to submit the JPK_MAG(2) file?

The JPK_MAG file is submitted at the request of the tax authority. Upon receiving a request, the company has at least 3 days to prepare and submit the file. In justified cases, it is possible to request an extension of this deadline.

Although three days is the minimum deadline stipulated by law, it is worth remembering that preparing the data may require the involvement of many departments within the organization. Therefore, readiness to generate the file should not be left until the moment a request is received.

Where to start preparing for JPK_MAG(2)?

For organizations using SAP, a good starting point is to analyze four key areas:

• how inventory data is linked to the KSeF number,
• the completeness of the data required for the PW and INW sections,
• the impact of the new structure on reporting processes,
• the system’s readiness to generate the required data.

This analysis allows you to identify potential data gaps early on and determine the scope of necessary changes.

Summary

JPK_MAG(2) is not merely an update to the report structure. For many organizations, it will require a review of how inventory data, financial data, and information from KSeF are linked.

The sooner this analysis is conducted, the easier it will be to assess the impact of the new requirements on business processes and the SAP environment before they take effect in 2027.

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