Polish VAT bad debt relief: the 90-day check before JPK

Polish VAT bad debt relief, called ulga na złe długi, lets a seller reduce the taxable amount and output VAT on an unpaid invoice once 90 days have elapsed after its payment deadline and the other conditions are met. A partial payment limits the relief to the unpaid portion. Before filing JPK_V7, check actual payments, VAT status and the correct reporting period, as well as the invoice age.

This guide covers the creditor: a business waiting for payment for a domestic Polish sale. The example assumes ordinary VAT accounting and a sale to an active VAT taxpayer. We checked the rules on 8 November 2026. A sole trader, or JDG, and a limited company, or sp. z o.o., can consider this VAT relief; their PIT or CIT treatment is a separate question.

When can a seller claim VAT bad debt relief?

The legal basis is Article 89a of Poland's VAT Act, consolidated text published in 2026. It covers supplies of goods and services within Poland. An overdue label in your accounting app does not establish eligibility on its own.

Check these conditions together:

• The receivable, or relevant portion, has not been settled or disposed of in any form within 90 days after the contractual or invoice payment deadline.
• You are registered as an active VAT taxpayer on the day before filing the return containing the adjustment.
• Three years have not elapsed, counted from the end of the year in which the invoice was issued.
• The amount covered by the relief remains unpaid and undisposed of up to filing the relevant return.

For the creditor, claiming relief is optional. Crossing the 90-day threshold does not oblige you to claim it. Keep evidence of the deadline, outstanding balance and eligibility checks before deciding.

Sales to consumers or buyers who were not active VAT taxpayers require additional analysis under Article 89a(2a). It sets additional conditions, such as entry of the receivable in a nationwide debt register. Do not automatically apply the B2B example below to those cases. Under cash accounting, also check whether and when output VAT was originally accounted for.

Which date starts the 90-day calculation?

Use the payment deadline, not the invoice issue date, the date OCR read the document, or its appearance in KSeF. Confusing these dates can put the adjustment in the wrong period. If the payment terms changed, retain the agreement supporting the date you use.

For example, an invoice is due on 15 July 2026. The 90th day after that deadline is 13 October 2026. For a business filing monthly VAT returns, October is therefore the relevant reporting period, provided the other conditions are met.

Check the balance again before filing. A payment received after day 90 but before submission cannot be ignored: you cannot claim relief on the paid amount. The Ministry of Finance's bad debt relief guidance explains the conditions and adjustment timing for both creditors and debtors.

How do you calculate relief after a partial payment?

Assume a domestic service invoice for PLN 10,000 net, PLN 2,300 VAT and PLN 12,300 gross, due on 15 July 2026. Both businesses are active VAT taxpayers, the seller has accounted for the sale, and the receivable has not been disposed of. The customer pays PLN 2,460 before day 90. No further payment arrives before the October JPK is filed. This is an illustrative calculation, not a Norman customer case.

The payment covers 20% of the invoice, leaving 80% unpaid. With a single 23% VAT rate:

If the seller elects to claim relief and meets all the conditions, the reduction is PLN 8,000 in the taxable amount and PLN 1,840 in output VAT. It is not PLN 2,300 of VAT, because part of the invoice has been paid. Nor does it automatically mean a PLN 1,840 refund to your bank account: the final balance depends on the whole VAT return.

For multiple VAT rates, a price correction or a payment covering several invoices, establish what the payment actually settles first. The simple percentage calculation above does not replace correct allocation to individual receivables.

What should you check in JPK_V7 before filing?

The adjustment must remain traceable to the specific invoice. It is not an unexplained reduction of total sales. The current Ministry of Finance brochure for JPK_V7M(3) and JPK_V7K(3), Table 8 and Examples 9 and 10 identifies these elements:

1. Invoice and counterparty details identifying the sale being adjusted.
2. Adjustment amounts separated by VAT rate. The initial relief is reported with negative amounts.
3. A value of 1 in KorektaPodstawyOpodt for the relevant creditor adjustment.
4. The payment deadline in TerminPlatnosci for an adjustment under Article 89a(1).
5. For subsequent payment or disposal: the event date in DataZaplaty and the corresponding increase.

The Polish field names help you check the output even when an app uses English labels. Do not edit XML solely from this checklist: also review the declaration section and its consistency with the records. The ministry's JPK questions and answers explain that these adjustments do not use the WEW internal-document marker.

How can AI help review unpaid invoices?

Start with a reliable outstanding balance. An unmatched bank transfer is not proof of non-payment. Money may have reached another account, been paid in cash or settled by offset, while an expired bank connection may have missed new transactions. AI can organize evidence and flag items for review; it should not fill gaps with assumptions.

Prepare a working list containing the invoice number, customer, due date, net and VAT amounts, allocated payments, remaining balance and source document. Keep missing information separate from confirmed non-payment. A useful document-analysis prompt is:

Compare the sales invoice list with payment confirmations. For each invoice, show the payment deadline, payments, outstanding balance and 90-day date. Do not match similar amounts without evidence identifying the invoice. Flag partial payments, missing statements and unclear settlements. Prepare a review list without deciding tax eligibility or submitting JPK.

This is a suggested AI workflow, not a claim that Norman automatically determines eligibility for bad debt relief. Norman's bank connection and CSV import help collect transactions and match them to invoices. After reconciliation, you still need to check the tax conditions and whether the particular adjustment has been correctly included in the file.

What if the customer pays later?

Return to the example. After relief has been claimed on PLN 9,840 gross, the customer pays PLN 4,920 in December, half the remaining debt. In the December return, increase the taxable amount by PLN 4,000 and output VAT by PLN 920. The outstanding balance is now PLN 4,920 gross.

Keep the original adjustment and the subsequent payment history. Do not erase the adjustment or make the invoice appear paid from the beginning. The record should explain why VAT amounts appear in different periods. Disposal of the receivable after claiming relief also requires the appropriate increase under Article 89a(4).

How do you complete the review in Norman?

Before approving a return, compare the receivables list with the correct reporting period. If an adjustment is missing or you cannot enter it correctly, resolve that with support or your accountant before filing. Marking an invoice unpaid does not prove that JPK has changed.

The JPK_V7 approval guide separates preparation, review of findings, approval and authorization for submission. After filing, check the status and UPO receipt. UPO confirms acceptance of the file; it does not confirm tax payment or the correctness of every entry. Our guide to how AI prepares taxes in Poland covers the wider preparation process.

Retain the supporting documents with the date of your final payment check. Revisit invoices covered by relief at the next month-end review so a later payment and the required output VAT increase are not missed.