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Poland e-invoicing

Poland E-Invoicing Mandate: What you need to know

Poland is rolling out a mandatory e-invoicing system known as KSeF (Krajowy System e-Faktur), which obligates businesses in the country to create, receive, and archive invoices electronically using a centralized platform managed by the government.

SAF-T System for Poland e-invoicing

Companies are required to submit their accounting data through the SAF-T (Standard Audit File for Tax) system. This system is used by the Polish Tax Authority (Urzad Skarbowy) to collect and review financial information electronically.

Timelines and Requirements

Under Poland e-invoicing mandate, B2B transactions will require mandatory e-invoicing starting February 1, 2026, for large taxpayers with annual revenues over 200 million PLN. The requirement will extend to all other taxpayers from April 1, 2026.

  • Format: B2B: XML FA(2) – current version; FA(3) – draft version , B2G: UBL 2.1, Peppol BIS 3.0
  • Digital Signature: Not mandatory
  • Archiving: Invoices must be archived for 5 years
Scope of e-invoicing

At present, e-invoicing is applicable to Business-to-Government (B2G) transactions. Additionally, the government introduced e-invoicing for Business-to-Business (B2B) transactions on a voluntary basis starting in January 2022. However, beginning 1 July 2024, it will become mandatory to issue e-invoices for B2B transactions. Enforcement through fines and penalties is set to commence from January 2025. Issuing invoices to consumers (B2C) through KSeF is optional. When used, consumers can retrieve their invoices by scanning a QR code.

Exemptions from e-invoicing:

In Poland e-invoicing is not mandatory for certain types of transactions. These include Business-to-Consumer (B2C) transactions, dealings with parties that do not have a Fixed Establishment (FE) in Poland, and transactions conducted under the EU One Stop Shop (OSS) or Import One Stop Shop (IOSS) schemes. Additionally, e-invoices are not required for toll receipts and railway tickets.

KseF – Poland e-invoicing portal

In Poland, the government has appointed the Krajowy System e-Faktur (KSeF) as the official Poland e-invoicing portal responsible for receiving, issuing, and storing structured electronic invoices. KSeF, also known as the National e-Invoice System, is Poland’s dedicated Electronic invoicing System and was developed by a state treasury-established firm called “Critical Applications.” The system validates e-invoices by checking the XML file structure for compliance with the logical template defined in the XSD format and verifying the authorisations to use the platform. However, it does not verify the factual correctness of the data, focusing solely on structural accuracy. KSeF has successfully passed a security audit, ensuring its compliance with security standards.

Everything You Need to Know About Poland E-Invoicing Process with KSeF

With Poland e-invoicing mandate rolling out via the Krajowy System e-Faktur (KSeF), businesses are navigating a new digital landscape for compliance. Whether you’re just getting started or looking for clarity on some finer points, here’s a simplified breakdown of how the system works and what you need to keep in mind.

Do I need to sign invoices before sending them to KSeF?

No digital signature is required when submitting invoices to KSeF. However, digital authentication is mandatory to access the KSeF portal. This ensures that the individual submitting the invoice has the appropriate authorization to act on behalf of the company.

What is considered the invoice date in KSeF?

The invoice date is the date the e-invoice is received and accepted by the KSeF system—not the date it was created.

Do I need to submit invoices to KSeF immediately after issuing them?

Not immediately. You have until the 15th day of the month following the taxable supply to submit the invoice.

Should the KSeF invoice number appear on printed invoices?

No, including the KSeF identifying number on the printout is not mandatory.

Can I attach supporting documents to the e-invoice?

No, attachments aren’t allowed in KSeF invoices. However, you can include a link within the invoice content pointing to external resources if needed.

What could cause an invoice to be rejected by KSeF?

Two common reasons for rejection are:

  • Incorrect invoice structure that doesn’t align with the system’s logical format.
  • Unauthorized submission, i.e., the person sending the invoice lacks the necessary permissions.
What happens if KSeF rejects an invoice?

If your invoice is rejected, it’s considered not issued. You’ll need to recreate and resubmit it with the corrected information. You cannot cancel or issue a correction for a rejected invoice.

Can I download multiple e-invoices at once?

Yes, bulk downloading is possible, but only in XML format.

Can I issue multiple corrective invoices for one sales invoice?

Yes, one can issue as many corrective invoices as needed for a single sales invoice.

Can I issue a proforma invoice through KSeF?

No. Proforma invoices aren’t recognized as official invoices under Poland’s VAT law, so they can’t be issued via KSeF

Can I use self-invoicing under KSeF?

Yes, self-invoicing is allowed—but the buyer must receive authorization from the seller, and this must be formally registered within KSeF.

Can invoices be shared with customers outside of KSeF?

Yes, once an invoice is approved by KSeF, you can send it to your customers directly. Just make sure the format and method of delivery are agreed upon between buyer and seller. Tools like ClearTax can help automate this.

What if KSeF is temporarily unavailable?

In case of a system outage, you must submit your e-invoice to KSeF within seven days after the system comes back online.

Do I still need to submit the JPK_VAT file if I’m using KSeF?

If you’re issuing all invoices via KSeF, there’s no need to submit the JPK_VAT file separately.

Navigating Poland e-invoicing system may seem complex at first, but once you understand the key rules, it becomes much more manageable. Staying compliant is not just about meeting deadlines—it’s also about understanding the logic of the system and using the right tools to streamline the process.

Preparing your business:

Businesses must thoroughly understand the KSeF mandate and ensure they are prepared to comply by the relevant deadlines. Technical readiness plays a key role, particularly in adapting internal systems to accommodate the FA_VAT format. To support a smooth transition, it is important to utilize available training and support resources. The requirement to include the KSeF number in payment references will have direct implications for accounting and payment processes, necessitating adjustments. While the optional use of offline mode and B2C e-invoicing offers additional flexibility, these options also demand careful evaluation. Ongoing monitoring of regulatory updates and official clarifications is essential to remain compliant. Moreover, it is important to consider that the National Revenue Administration (Krajowa Administracja Skarbowa, KAS) may use data from the KSeF system during their proceedings.

What next?

  • Analyze KSeF’s impact on existing invoicing processes.
  • Update ERP and accounting systems to align with FA_VAT schema requirements.
  • Train relevant teams on compliance procedures.
  • Track regulatory updates from the Polish Ministry of Finance.
  • Enable system capability for handling KSeF e-invoice attachments.
  • Prepare for QR code certificate issuance and retrieval.
  • Contribute to public consultations on the draft Act and technical specs, if applicable.
How can we help?

Anusaar is a certified Peppol Access Point, equipped to support businesses in seamlessly integrating and automating electronic invoices and other business documents. With extensive experience in integration and automation, our team of seasoned professionals offers expert assessment and gap analysis to identify your specific needs. We provide tailored solutions designed to enhance efficiency, ensure compliance, and streamline your invoicing processes. Let us help you navigate the path of Poland e-invoicing with ease.