Does every invoice need a GTU code?

No, and that's the rule rather than the exception. GTU markers cover thirteen closed groups of goods and services listed in § 10 ust. 3 of the regulation on the detailed scope of data in VAT returns and records. Ordinary software sales, construction work, graphic design and passenger transport fall into none of them. Most invoices carry no GTU at all, and that is correct.

GTU (grupa towarów i usług, goods-and-services group) marks sales that are especially exposed to VAT fraud. There are thirteen codes: GTU_01 to GTU_10 for goods and GTU_11 to GTU_13 for services. Their scope is set by § 10 ust. 3 of the Minister of Finance regulation of 15 October 2019.

When does GTU_12 apply?

GTU_12 covers intangible services from a closed list: advisory, accounting and financial audit, legal, management, head office, marketing and advertising, market and public opinion research, scientific research and development, and non-school forms of education. The regulation enumerates them by PKWiU 2015 codes, so the classification of the service decides, not the wording on the invoice.

Does an IT service need GTU_12?

It depends on what you actually do. Programming and software implementation (PKWiU 62.01) is not on the list, so there's no GTU. IT advisory (PKWiU 62.02.1 and 62.02.2), management of IT systems (62.03) and website management, i.e. hosting (63.11.12), are on the list and take GTU_12.

Where does the GTU code sit on a structured invoice?

In the FA(3) schema, GTU is a field on a single invoice line, inside the FaWiersz element. It is optional and takes one value per line. Procedure markers such as WSTO_EE or B_SPV have their own Procedura field next to it, and the TP flag sits at whole-invoice level.

What happens if you get a GTU marker wrong?

The head of the tax office calls on you to correct the records and points out the errors (art. 109 ust. 3f of the VAT Act). You have 14 days to correct them or explain that there is no error. Only if you do neither does a penalty of 500 zł per error follow (art. 109 ust. 3h). The penalty does not apply to a sole trader who bears fiscal-offence liability for the same act.

GTU codes on an invoice: the full GTU_01–GTU_13 list

GTU markers flag sales that are especially exposed to VAT fraud. There are thirteen of them: GTU_01 to GTU_10 for goods, GTU_11 to GTU_13 for services. Each scope is set by § 10 ust. 3 of the regulation on the detailed scope of data in VAT returns and records. Most invoices need none of them, and in the FA(3) schema the code now sits on the invoice line itself, not only in JPK.

What GTU codes are

The Minister of Finance carved out thirteen groups of goods and services so that VAT records can identify the areas where abuse occurs or which are exposed to it (that is the wording of the delegation in art. 109 ust. 14 of the VAT Act). Fuels, alcohol, electronics, metals, intangible services. Sales from those groups have to be marked with a code so they can be filtered out without reading the invoices. That's the whole mechanism. GTU does not change the rate, does not change when the tax point arises, and has nothing to do with split payment.

Two things before you get to the list.

GTU applies to sales only. On the purchase side you mark nothing, even if you bought an item from the list. It marks output tax, not input tax.

Most invoices carry no GTU. The list is closed and narrower than it looks. Programming, graphic design, translation, construction work, passenger transport, courier services, a SaaS subscription: none of these has a code. An extra marker is just as much an error as a missing one.

The full GTU code list

The scopes below follow § 10 ust. 3 of the regulation of the Minister of Finance, Investment and Development of 15 October 2019, as amended with effect from 1 July 2021 and 1 January 2023. Annex item numbers and CN codes are quoted literally, because the classification turns on them.

Goods: GTU_01 to GTU_10

Code	What it covers	Detail
`GTU_01`	Alcoholic beverages	Beverages with alcohol content above 1.2%, beer, and mixtures of beer and non-alcoholic drinks with alcohol content above 0.5% (CN 2203 to 2208).
`GTU_02`	Motor fuels	The closed list of goods in art. 103 ust. 5aa of the VAT Act: petrols, diesel oils, motor gases, biofuels.
`GTU_03`	Heating and lubricating oils	Heating oils not covered by GTU_02, lubricating oils and other oils (CN 2710 19 71 to 2710 19 83 and 2710 19 87 to 2710 19 99, excluding plastic greases under CN 2710 19 99), lubricating oils CN 2710 20 90, lubricating preparations CN 3403 (excluding plastic greases within that heading).
`GTU_04`	Tobacco products	Tobacco products, dried tobacco, e-cigarette liquid and novel products within the meaning of the excise duty rules.
`GTU_05`	Waste	Only the waste specified in items 79–91 of Annex 15 to the VAT Act.
`GTU_06`	Electronic devices and parts and materials for them	Only goods from items 7, 8, 59–63, 65, 66, 69 and 94–96 of Annex 15, plus stretch film from item 9 of that annex.
`GTU_07`	Vehicles and parts	CN codes 8701 to 8708.
`GTU_08`	Precious and base metals	Only goods from items 1 and 1a of Annex 12 and from items 12–25, 33–40, 45, 46, 56 and 78 of Annex 15.
`GTU_09`	Medicines and medical devices	Medicinal products, foodstuffs for particular nutritional uses and medical devices, only those subject to the notification duty under art. 37av ust. 1 of the Pharmaceutical Law.
`GTU_10`	Real property	Buildings, structures and land, together with their parts and shares in ownership, including the disposal of rights referred to in art. 7 ust. 1 of the VAT Act.

Inside GTU_06, stretch film is the one item with nothing to do with electronics. It arrived with the July 2021 amendment, and the name of the code does not point to it, so it's easy to miss.

GTU_10 covers the supply of real property. Renting a unit is a service, not a supply, and takes no code here. Neither does construction work.

Services: GTU_11 to GTU_13

Code	What it covers	Detail
`GTU_11`	Transfer of greenhouse gas emission allowances	Allowances within the meaning of the Act of 12 June 2015 on the greenhouse gas emission allowance trading scheme.
`GTU_12`	Intangible services	A closed list enumerated by PKWiU 2015 codes: advisory (including legal, tax and management advisory), accounting and financial audit, legal, management, head office, marketing or advertising, market and public opinion research, scientific research and development, non-school forms of education.
`GTU_13`	Transport and warehousing services	Only PKWiU 49.4 and 52.1.

The name of GTU_12 sounds capacious; the text of the provision is not. The regulation does not stop at the phrase "services of an intangible character", it enumerates specific PKWiU groupings:

advisory: 62.02.1, 62.02.2, 66.19.91, 69.20.3, 70.22.11, 70.22.12, 70.22.13, 70.22.14, 70.22.15, 70.22.16, 70.22.3, 71.11.24, 71.11.42, 71.12.11, 71.12.31, 74.90.13, 74.90.15, 74.90.19,
accounting and financial audit: 69.20.1, 69.20.2,
legal: 69.1,
management: 62.03, 63.11.12, 66.11.19, 66.30, 68.32, 69.20.4, 70.22.17, 70.22.2, 90.02.19.1,
head offices: 70.1,
marketing or advertising: 73.1,
market and public opinion research: 73.2,
scientific research and development: 72,
non-school forms of education: 85.5.

If your service is not in one of those groupings, GTU_12 does not apply to it. Not even if it is intangible, digital and sold remotely.

Where GTU sits in the FA(3) schema

Polish accounting guides describe GTU as a JPK_V7 matter, because that is where the obligation started. In the FA(3) schema it looks different.

In VAT records the marker sits on the whole document: one invoice, one record row, a full set of flags. The GTU field in FA(3), by contrast, belongs to the FaWiersz element, that is to a single invoice line, and takes one value per line. For order rows in a prepayment invoice the equivalent is GTUZ. An invoice with ten lines can therefore carry ten different markers, or none.

The same line also carries the fields the GTU derives from: PKWiU, CN, PKOB, GTIN and Indeks, and alongside them the P_12_Zal_15 flag for goods and services from Annex 15 to the Act. The classification symbol and the marker that follows from it sit in one place rather than in two different systems. If anyone ever asks why that particular code, the answer is on the same line.

In practice:

The marker travels with the invoice rather than separately. Before KSeF became mandatory, GTU was a classic month-end job: the bookkeeper received the invoices and tagged them before filing JPK. Now the XML you send to KSeF can already carry that information, and accounting software reads it straight from the structure. Knowledge of what you sell moves from the accounting firm to the system that issues the invoice.
One line, one code. A single record row can carry several GTU flags at once, because it describes the whole invoice. The GTU field in FaWiersz takes exactly one value. If one invoice line mixes two groups, split it into two lines. That is clearer for the buyer anyway.
The field is optional. In the FA(3) schema GTU has minOccurs="0". The statutory obligation still lives in the records under art. 109 ust. 3 of the VAT Act, not in the catalogue of invoice elements in art. 106e. An empty field will not get the invoice rejected by KSeF.
You cannot fix an invoice once it's filed. If it went to KSeF with an empty or wrong field, the marker has to be put right on the JPK side, because the records must be correct regardless. The difference is that the tax office now holds both sides at once: the invoice from KSeF and the records from JPK.

If you are still designing your issuing process, start with how to issue a structured invoice, and the rollout dates are in KSeF mandatory in 2026.

Which code for my service

Classification follows PKWiU, not the wording on the invoice. "Consulting services" in a line description does not create GTU_12, and "project support" can hide it. The most common cases below.

Service	Code	Why
Marketing, advertising, campaigns, social media	`GTU_12`	PKWiU 73.1 is explicitly on the list.
Market research, surveys, opinion polling	`GTU_12`	PKWiU 73.2.
Business, legal, tax and management advisory	`GTU_12`	Advisory is named explicitly, including legal, tax and management-related advisory.
Bookkeeping, financial audit	`GTU_12`	PKWiU 69.20.1 and 69.20.2.
Legal services, law firm work	`GTU_12`	PKWiU 69.1.
Training and courses outside the school system	`GTU_12`	PKWiU 85.5, non-school forms of education.
IT advisory, IT audit, system architecture	`GTU_12`	PKWiU 62.02.1 and 62.02.2.
Network and IT system management	`GTU_12`	PKWiU 62.03, on the management services list.
Hosting and website management	`GTU_12`	PKWiU 63.11.12 is also among management services, though the name doesn't suggest it.
Research and development work	`GTU_12`	The whole PKWiU division 72.
Property management on commission	`GTU_12`	PKWiU 68.32.
Programming, implementation, software maintenance	none	PKWiU 62.01 was not listed.
SaaS subscription, software licence	none	Outside every grouping on the list.
Road freight transport, forwarding	`GTU_13`	PKWiU 49.4.
Warehousing and storage of goods	`GTU_13`	PKWiU 52.1.
Passenger transport: taxi, coach, staff transport	none	PKWiU 49.3, outside the scope of GTU_13.
Courier and postal services	none	PKWiU division 53, outside the scope.
Graphic design, UX, visual identity	none	PKWiU 74.1 is not listed.
Translation	none	PKWiU 74.3 is not listed.
Construction and renovation work	none	GTU_10 covers the sale of real property, not work done on it.
Lease and tenancy of premises	none	That is a service, and GTU_10 covers supply.

The border between "IT advisory" and "programming" is thin, and one contract often covers both. What settles it is the character of the supply, not the split of hours. If you are unsure of the grouping, the statistical office in Łódź issues PKWiU classification opinions. Get one in writing if you invoice the same service hundreds of times a year.

Common mistakes

Marking everything just in case. The tax office then sees risk-group sales where there are none, and the records are wrong in exactly the same way as with a missing code.

Confusing GTU with procedure markers. These are two different sets. GTU says what you sell. Procedure markers say under what regime: WSTO_EE, IED, TT_D, I_42, I_63, B_SPV, B_SPV_DOSTAWA, B_MPV_PROWIZJA. In FA(3) they have their own Procedura field next to GTU, and the related-party flag TP sits higher still, at whole-invoice level. One transaction can need a GTU code and a procedure marker at the same time.

Looking for the "MPP" marker. It has been gone since 1 July 2021, when it was repealed as a records flag. The "mechanizm podzielonej płatności" annotation on the invoice itself is an entirely separate obligation and still applies.

Marking aggregate documents. Under § 10 ust. 3a of the regulation, GTU does not apply to transactions entered on the basis of RO (cash register report) and WEW (internal document) evidence. Bad-debt-relief corrections (art. 89a ust. 1 and 4 of the VAT Act) are not marked either.

Skipping prepayments. A prepayment towards a supply from the list concerns the same goods or the same service, so the marker is already due on the prepayment invoice. In the FA(3) schema, order rows have their own GTUZ field for it.

Losing the marker on a correction. A credit note against a sale from the list concerns the same goods or service, so the marker does not disappear from it. How a correction looks in the KSeF schema is covered in the KOR credit note.

What an error costs. If the head of the tax office finds errors in the filed records that prevent verification of a transaction, they call on you to correct them and point them out specifically (art. 109 ust. 3f of the VAT Act). You have 14 days to correct them or to explain that there is no error (ust. 3g). Only a failure to respond ends in a penalty of 500 zł per error (ust. 3h). The penalty does not apply to a sole trader who bears liability for a fiscal offence or fiscal crime for the same act (ust. 3i).

GTU and selling through Stripe

Stripe knows nothing about Polish goods-and-services groups. The invoice payload has no field a GTU could be derived from, and nothing that would let you read a PKWiU classification out of a product name. That's why KSeF Kit does not set GTU markers on the invoices it files: we build FA(3) from what Stripe actually knows, and the marker stays on your side, in your VAT records.

For most Stripe sales that's not a problem: a SaaS subscription, a licence or app access carries no code at all. If, on the other hand, you sell advisory, training, marketing or hosting, the marker has to reach JPK from your side. What else you need to add to Stripe's data is set out in the Stripe and KSeF integration, and foreign sales in the export invoice.