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JMHZ – Further Planned Development and Known Limitations

Overview of Current Limitations and Planned Improvements for VAT Support in ABRA Flexi

Written by Hana Straková

Support for JMHZ in ABRA Flexi was developed based on the information available from the Czech Social Security Administration (ČSSZ) and the Ministry of Labour and Social Affairs (MPSV).

Because the JMHZ specifications and methodology were released gradually, often with delays, and in some cases lacking full clarity, it was not possible for us to cover every scenario with 100% accuracy in the first version.

We have been continuously working on the implementation and will continue to iteratively refine and expand it as new information becomes available and based on real-world feedback.


🔧 Ongoing fixes and updates

Released versions progressively include fixes and behavioral improvements based on:

  • clarifications to the methodology from ČSSZ / MPSV

  • real-world data and situations from customers

  • identified discrepancies during report submissions

Individual fixes will always be described in more detail in the changelog.


🚧 Known limitations and areas of further development

Below is a list of areas that have already been resolved, are currently in development, or are planned for future versions:

Description

Status

Fixed in version

JMHZ Viewer – Municipality of workplace (10229) may not exactly match the value from the code list

🟢 Done

MH – added validation when weekly working hours are not filled in

🟢 Done

MH – incorrect population of attribute 10261 (Stipulated weekly working hours of the employee) for statutory bodies

🟢 Done

MH – deferred income carry-through for "standard" employment

🟢 Done

2026.3.19

MH – non-functional cancellation

🟢 Done

2026.3.19

Complete validations for 6-ODM. NEREZ. VNE EU so that the ELDP code is required

🟢 Done

2026.3.18

Employment record import – learn to retrieve the personal number from the person column

🟢 Done

2026.3.18

MH – add validation that the weekly working hours are known

🟢 Done

2026.3.18

JMHZ print output files are overwritten without warning

🟢 Done

2026.3.18

MH – unusual behavior of the MH wizard when alternating between "Next" and "Back"

🟢 Done

2026.3.18

MH – add validation that the employment start date is filled in

🟢 Done

2026.3.18

MH – attribute 10373 Reduced working hours scope should not be included for students

🟢 Done

2026.3.18

MH – error M28 when using the JUBILEUM pay component

🟢 Done

2026.3.17

MH – error M36 in the case of overtime without overtime supplements

🟢 Done

2026.3.17

MH – add option to save in ZIP format

🟢 Done

2026.3.16

MH – incorrect calculation of excluded days in the case of a combination of full-month absence and bonuses

🟢 Done

2026.3.16

MH – incorrect counting of absence days when absence extends more than 1 day into the current month and absence hours are filled in for the first day

🟢 Done

2026.3.16

MH – replace summing of paid leave 1–5 with the use of TOTAL PAID LEAVE

🟢 Done

2026.3.16

MH – non-resident with a signed taxpayer declaration generates invalid XML

🟢 Done

2026.3.15

MH – improve display of available submitted MH records

🟢 Done

2026.3.15

MH – review attributes conditional on the number of ELDP days

🟢 Done

2026.3.15

MH – use of incorrect person settings within the MH

🟢 Done

2026.3.15

MH – error M1 – incorrect application of social insurance discount for employees who had no income for the entire month

🟢 Done

2026.3.15

JMHZ – unable to set access rights for REGZEC and MH independently

🟢 Done

2026.3.14

MH – supplement-related elements (10332–10336) should only be populated when non-zero

🟢 Done

2026.3.14

MH – incorrect population of attribute Monthly child tax credit (10304)

🟢 Done

2026.3.14

MH – added validation that SP, health insurance, and tax bases must not have negative values

🟢 Done

2026.3.13

REGZEC – validation of the Early Termination Reason field when Free Access to the Labour Market is selected

🟢 Done

2026.3.13

Stipulated fund – value from Company Settings is not propagated to the employment record

🟢 Done

2026.3.13

REGZEC – A1 – foreign nationals with ikMpsv

🟢 Done

2026.3.13

MH – error M255 – Primary employment relationship: No primary PPV exists for the OIČ within the submission.

🟢 Done

2026.3.13

MH – error M59 – if absence covers the entire month, the assessment base (10245) should not be filled in

🟢 Done

2026.3.13

MH – fix for error: Settled wage is less than the tariff wage when using Deduction for excess holiday taken (20028) and bonuses

🟢 Done

2026.3.13

REGZEC – add length validations

🟢 Done

2026.3.12

REGZEC – missing address data for employees with a permanent residence abroad

🟢 Done

2026.3.12

Unable to delete the Stipulated Fund value on an employment record

🟢 Done

2026.3.12

MH – error 20248, 20321 (M248, M321) – population of employee summary data for a non-primary employment record

🟢 Done

2026.3.12

MH – corrective submission – error M8 – not all selected employment records are used

🟢 Done

2026.3.12

Add new deduction type DEDUCTION UNDER THE CIVIL CODE

🟢 Done

2026.3.11

Social insurance calculation for employees should be per employment record

🟢 Done

2026.3.11

REGZEC – adjustment of the Duration of pension insurance population

🟢 Done

2026.3.11

REGZEC – employment type (typeempl) should not be filled in certain cases

🟢 Done

2026.3.11

REGZEC – action A2 – add validation that wages must have been calculated

🟢 Done

2026.3.11

REGZEC – pension data will only be populated if the pension is outside ČSSZ

🟢 Done

2026.3.11

MH – add a warning that social insurance checks have not been met

🟢 Done

2026.3.11

MH – invalid XML for a non-resident with withholding tax advance

🟢 Done

2026.3.11

MH – adjust the places where the social insurance base component is used in calculations

🟢 Done

2026.3.11

MH – use Civil Code deductions for populating attribute 10116

🟢 Done

2026.3.11

MH – holiday wage compensation amount does not match the amount in Wage Update

🟢 Done

2026.3.10

MH wizard – the list of employment records does not refresh when the opening step is changed; it appears empty

🟢 Done

2026.3.10

MH – incorrect identification of the primary PPV when Flexi contains multiple main employment records

🟢 Done

2026.3.10

REGZEC – include the company name in the file name

🟢 Done

2026.3.10

REGZEC – A3 – some employment record attributes are not populated

🟢 Done

2026.3.10

REGZEC – remove line breaks from the Issuing authority (foreigninst) field

🟢 Done

2026.3.10

REGZEC – map termination reason 5d to 5

🟢 Done

2026.3.10

JMHZ – display of additional employment record details

🟢 Done

2026.3.10

MH – error 20332 – incorrect identification of the primary PPV

🟢 Done

2026.3.9

Automatically send the Flexi customer number to the JMHZ Viewer

🟢 Done

2026.3.9

Unable to create an MH for employment type 6-ODM. NEREZ. VNE EU

🟢 Done

2026.3.9

MH – error 40244, 40245 – certain data must not be filled in when the declaration has not been signed

🟢 Done

2026.3.9

MH – error 40242 – withholding tax data must not be included when the declaration has been signed

🟢 Done

2026.3.9

MH – error 40325 – withholding tax attributes are shown even when agreements are taxed by advance tax

🟢 Done

2026.3.9

MH – error 40243 – the taxpayer declaration section must not be included for non-residents

🟢 Done

2026.3.9

MH – other income

🟢 Done

2026.3.8

MH – fix for error: Settled wage is less than the tariff wage when using Deduction for excess holiday taken (20028)

🟢 Done

2026.3.8

JMHZ documents lose formatting after being opened in the JMHZ Viewer

🟢 Done

2026.3.8

REGZEC – incorrectly highlighted field when Pension received since is not filled in

🟢 Done

2026.3.8

MH – error 20267 – when the Settled wage for work value is zero, other attributes must not be populated

🟢 Done

2026.3.7

MH – error 20329 – if no excluded periods are reported, the excused absence reason data must not be filled in

🟢 Done

2026.3.7

MH for January – contributions to retirement savings products are not reflected

🟢 Done

2026.3.7

MH – attribute 10416 should be conditional on non-resident status

🟢 Done

2026.3.7

MH – net income must not be negative

🟢 Done

2026.3.7

MH – error 20283 – when settled income is zero, related attributes must not be populated

🟢 Done

2026.3.7

REGZEC – national ID number should be set only for Czech citizenship

🟢 Done

2026.3.7

REGZEC – fixed-term contract – element zamestnaniUkoncenoSmrti = NO is always populated

🟢 Done

2026.3.7

REGZEC – remove spaces from address number fields

🟢 Done

2026.3.6

REGZEC – remove line breaks from workplace location fields

🟢 Done

2026.3.6

REGZEC – end date is incorrectly included for the commencement action

🟢 Done

2026.3.6

REGZEC – offering employment records whose start date differs from the active from date

🟢 Done

2026.3.6

MH – incorrect social insurance calculation in the MH header when social insurance discounts exist (errors 20012, 20013)

🟢 Done

2026.3.6

REGZEC XML – populate the terminated by death element

🟢 Done

2026.3.6

MH – error 20307 – when the ELDP code is not filled in, pension insurance period data is incorrectly populated

🟢 Done

2026.3.5

MH – added ELDP code validation

🟢 Done

2026.3.5

MH – error 20099 Date is outside the month for which the report is being submitted

🟢 Done

2026.3.5

REGZEC – allow registration of employment records that were not previously registered

🟢 Done

2026.3.5

REGZEC – cancellation action contains extra data

🟢 Done

2026.3.5

MH – error 20028 when travel expenses within the limit are used

🟢 Done

2026.3.5

MH – change the way XML namespaces are used (aliases)

🟢 Done

2026.3.4

MH – error 20286 – errors in the inclusion of elements for unworked hours when there are no unworked hours

🟢 Done

2026.3.4

MH – clarify the "Was it submitted?" prompt

🟢 Done

2026.3.4

MH – error 20158 – ELDP code is not from the code list

🟢 Done

2026.3.4

MH – sick pay compensation should be included in settled wage (10328)

🟢 Done

2026.3.4

JMHZ – errors in CSV import with OIČ, PPV ID

🟢 Done

2026.3.3

REGZEC – fix for population of postal codes containing spaces

🟢 Done

2026.3.3

JMHZ – CSV import – multiple employment records with the same code

🟢 Done

2026.3.3

MH – 10259 – stipulated fund for irregular working hours contains an incorrect number

🟢 Done

2026.3.3

MH – agreed fund for irregular working hours

🟢 Done

2026.3.3

MH – error 20235 – incorrect number of forms in the batch

🟢 Done

2026.3.3

The JMHZ add-on pre-populates with data when opened directly from Flexi

🟢 Done

2026.3.2

REGZEC A3 additional registration – change of country of residence from (10459) will always be populated

🟢 Done

2026.3.2

REGZEC – if Health limitation type is filled in, the Work performed mainly attribute must also be filled in

🟢 Done

2026.3.2

Relaxed residence validation for CZ tax residents in REGZEC

🟢 Done

2026.3.1

MH – number of days of temporary incapacity for work should be in calendar days

🟢 Done

2026.3.1

JMHZ Viewer – duplicate PPV ID is not highlighted when a duplicate PPV ID is detected (error M251)

🟢 Done

jmhz-viewer-2026-05-26

JMHZ Viewer – display GUID

🟢 Done

jmhz-viewer-2026-05-26

JMHZ Viewer – disable checks for the Cancellation action

🟢 Done

jmhz-viewer-2026-05-20

JMHZ Viewer – focus is on the wrong field for certain elements

🟢 Done

jmhz-viewer-2026-05-20

JMHZ Viewer – review check M343 in the case of deferred income

🟢 Done

jmhz-viewer-2026-05-20

JMHZ Viewer – review rounding in check 315

🟢 Done

jmhz-viewer-2026-05-20

JMHZ Viewer – review check M242

🟢 Done

jmhz-viewer-2026-05-20

JMHZ Viewer – review check for action A8 REGZEC

🟢 Done

jmhz-viewer-2026-05-20

JMHZ Viewer – fix display of deferred income

🟢 Done

jmhz-viewer-2026-05-15

JMHZ Viewer – fix sanitization on save

🟢 Done

jmhz-viewer-2026-05-15

JMHZ Viewer – fix IK MPSV validation

🟢 Done

jmhz-viewer-2026-05-15

JMHZ Viewer – update MH checks

🟢 Done

jmhz-viewer-2026-05-15

JMHZ Viewer – review check R172 for action A2

🟢 Done

jmhz-viewer-2026-05-07

JMHZ Viewer – municipality names are not required to match the exact value from the code list

🟢 Done

jmhz-viewer-2026-05-07

JMHZ Viewer – incorrect values in the Work performed mainly code list

🟢 Done

jmhz-viewer-2026-05-05

JMHZ Viewer does not recognize 'Ž' as a valid value in the gender code list (error R16)

🟢 Done

jmhz-viewer-2026-05-04

JMHZ Viewer – validation – add checks for specific code list values

🟢 Done

jmhz-viewer-2026-04-30

JMHZ Viewer – API for code lists

🟢 Done

jmhz-viewer-2026-04-30

JMHZ Viewer – review check R100 when Termination reason is not specified

🟢 Done

jmhz-viewer-2026-04-30

JMHZ Viewer – fix checks M325 and M245

🟢 Done

jmhz-viewer-2026-04-30

JMHZ Viewer – data checks for employees with a permanent residence abroad

🟢 Done

jmhz-viewer-2026-04-30

JMHZ Viewer – incorrect check M229 for the 4th and subsequent child tax credit

🟢 Done

jmhz-viewer-2026-04-30

JMHZ Viewer – option to load metadata from the official ČSSZ CSV file

🟢 Done

jmhz-viewer-2026-04-30

JMHZ Viewer – improvements to sanitization and XML generation

🟢 Done

jmhz-viewer-2026-04-30

JMHZ Viewer – ZIP support in embedded mode (external integration)

🟢 Done

jmhz-viewer-2026-04-30

JMHZ Viewer – fix sorting and saving of children

🟢 Done

jmhz-viewer-2026-04-30

JMHZ Viewer – review REGZEC validation – pension type + pension received since

🟢 Done

jmhz-viewer-2026-04-23

JMHZ Viewer – review K229 when there are multiple children for whom the tax credit is not applied

🟢 Done

jmhz-viewer-2026-04-23

JMHZ Viewer – option to load and save a ZIP file

🟢 Done

jmhz-viewer-2026-04-23

JMHZ Viewer – option to display additional employee information

🟢 Done

jmhz-viewer-2026-04-23

JMHZ Viewer – support for passing a parameter with the Flexi customer number

🟢 Done

jmhz-viewer-2026-04-23

JMHZ Viewer – validation of field obligations (columns I–X)

🟢 Done

jmhz-viewer-2026-04-23

JMHZ Viewer – add checks for REGZEC attachments

🟢 Done

jmhz-viewer-2026-04-23

JMHZ Viewer – empty elements after deleting a value cause XSD errors

🟢 Done

jmhz-viewer-2026-04-23

JMHZ Viewer – check R50 – perform only for action A3

🟢 Done

jmhz-viewer-2026-04-23

JMHZ Viewer – review the check for permanent address completion for Slovak nationals

🟢 Done

jmhz-viewer-2026-04-23

JMHZ Viewer – review checks M214 and M215

🟢 Done

jmhz-viewer-2026-04-17

JMHZ Viewer – review check R201

🟢 Done

jmhz-viewer-2026-04-17

JMHZ Viewer – add further MH checks

🟢 Done

jmhz-viewer-2026-04-16

JMHZ Viewer – REGZEC – validation of Specific obligations (column F)

🟢 Done

jmhz-viewer-2026-04-16

JMHZ Viewer – REGZEC – validation of Logical checks (column G)

🟢 Done

jmhz-viewer-2026-04-16

JMHZ Viewer – REGZEC – validation of Obligation conditions (columns Y–AA)

🟢 Done

jmhz-viewer-2026-04-16

JMHZ Viewer – cover existing MH checks with tests

🟢 Done

jmhz-viewer-2026-04-16

JMHZ Viewer – fix loading of XML files with windows-1250 encoding

🟢 Done

jmhz-viewer-2026-04-16

JMHZ Viewer – support for multiple files at once

🟢 Done

jmhz-viewer-2026-04-16

JMHZ Viewer – UI fixes and improvements

🟢 Done

jmhz-viewer-2026-04-10

JMHZ Viewer – some basic checks are not triggered when automatically opened from Flexi

🟢 Done

jmhz-viewer-2026-04-10

JMHZ Viewer – discount data is not displayed in the header

🟢 Done

jmhz-viewer-2026-04-10

JMHZ Viewer – does not report error 329

🟢 Done

jmhz-viewer-2026-04-10

JMHZ Viewer – review K42

🟢 Done

jmhz-viewer-2026-04-10

JMHZ Viewer – dialog for reporting an issue

🟢 Done

jmhz-viewer-2026-04-10

JMHZ Viewer – improvements to XLS export

🟢 Done

jmhz-viewer-2026-04-10

JMHZ Viewer – save to PDF

🟢 Done

jmhz-viewer-2026-04-08

JMHZ Viewer – implementation of REGZEC attachments

🟢 Done

jmhz-viewer-2026-04-08

JMHZ Viewer – review check K37 for IK MPSV

🟢 Done

jmhz-viewer-2026-04-08

JMHZ Viewer – checks K284, K216, K7 do not respect the employment record type

🟢 Done

jmhz-viewer-2026-04-08

JMHZ Viewer – review check K332

🟢 Done

jmhz-viewer-2026-04-08

JMHZ Viewer – tighten check K99

🟢 Done

jmhz-viewer-2026-04-08

JMHZ employment record import error from Excel fails – when importing without a PPV ID that is already set on the employment record in Flexi

🔵 In development

MH – populate annual settlement result data (attributes 10321, 10322, 10323)

🔵 In development

MH, REGZEC – use company name in the file name

🔵 In development

PREZEC – Pre-registration of employees from 1 July 2026

🔵 In development

New endpoint in Flexi for displaying the JMHZ Viewer

🔵 In development

MH – include national ID numbers of children and persons maintaining the same children only if valid

🔵 In development

MH – incorrect population of attributes 10268 and 10276 when there are public holidays in the month

🔵 In development

JMHZ Viewer – improve the error message when prohibited fields are filled in

🔵 In development

Add stipulated fund to JMHZ exports and imports

🔴 Closed

MH – error 20028 Settled wage is less than the sum of its components

🔴 Closed

MH – errors 20001, 20207 – errors related to social insurance discounts for the employer

🔴 Closed

JMHZ Viewer – review K255 – validation of primary PPV for an employee with multiple employment records

🔴 Closed

JMHZ Viewer – Excel spreadsheet cannot be opened in a spreadsheet application on macOS

🔴 Closed

JMHZ Viewer – verify that XML format validation correctly validates optional elements

🔴 Closed

Absence – Unpaid leave – attributes 10358, 10359, 10360, 10362 must not be populated

🔴 Closed

MH – error 20013 in the case of multiple employment records

🔴 Closed

MH – enable finding an employment record by GUID from the submission

🔴 Closed

REGZEC – add validation for the Work performed mainly field

🔴 Closed

JMHZ Viewer – may not report an error when Work performed mainly is not filled in

🔴 Closed

Add a "Wage payment date" field to the monthly report wizard

⚪ Planned

MH – excluded periods reported in the ELDP section

⚪ Planned

MH – employees receiving a pension and ELDP

⚪ Planned

REGZEC – change action and multiple person/employment record settings in one month

⚪ Planned

MH – invalid XML when employee data is not filled in

⚪ Planned

MH – remove the "full pension" condition

⚪ Planned

MH – do not offer employment records that do not have a ČSSZ employment code filled in

⚪ Planned

MH – annual settlement result

⚪ Planned

JMHZ Viewer – write-back saving of XML

⚪ Planned

JMHZ – improvements to the generated file name

⚪ Planned

JMHZ Viewer – add a summary row directly on the page

⚪ Planned

MH – refine support for prisoners

⚪ Planned

MH – error M59 for pensioners – assessment base for periods around reaching retirement age (points 3 and 4)

⚪ Planned

New employment type: Procurist

⚪ Planned

HR – OIČ should be unique

⚪ Planned

MH – adjust the name of generated files

⚪ Planned

JMHZ Viewer – add the option to merge Monthly Report XML files from multiple payroll offices

⚪ Planned

JMHZ Viewer – enable working with a cursor

⚪ Planned

MH – Deferred income and contributions to retirement savings products

⚪ Planned

MH – support for staffing agencies

⚪ Planned

JMHZ Viewer – support for PREZEC

⚪ Planned

Make REGZEC output available via API (testability)

⚪ Planned

Refactor submission type on MH tables to a localized code list

⚪ Planned


🔁 Our approach

  • we continuously monitor changes and new information from ČSSZ and MPSV

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