Poland e-Invoicing FAQs: Everything You Need to Know

The Polish government intended to implement e-invoicing from 1 January 2024 and issued the draft regulations accordingly. However, it postponed the implementation date to 1 July 2024.

The Polish Ministry of Finance (MoF) states that the e-invoicing initiative significantly changes business operations. Further, Large enterprises that have already started the implementation process are witnessing the complications, time and resources spent on e-invoicing.

Accordingly, the businesses which have started implementation or are planning to implement the e-invoicing might have many questions. This article lists the Frequently Asked Questions (FAQs) and answers.

Basics of Poland e-invoicing

What is an e-invoice?

Invoice data filled in a specified logical structure and validated by authority is called an e-invoice.

What is e-invoicing in Poland?

The process of submitting an e-invoice to the authority (KSeF) is called e–invoicing.

Who is the e-invoicing authority in Poland?

The Polish Ministry of Finance (MoF) oversee the implementation of e-invoicing in Poland.

What documents fall under e-Invoicing?

Currently, Business to Government (B2G) transactions fall under e-invoicing. Further, the government has initiated e-invoicing on a voluntary basis for Business to Businesses (B2B) transactions in January 2022. However, it is mandatory to generate e-invoices for B2B transactions from 1 July 2024. Fines and penalties will be applicable from January 2025.

Are there any exemptions for Poland e-invoicing?

You don’t have to generate e-invoices in Poland for 

• Business to Consumer (B2C) transactions
• Transactions with a person not having a Fixed Establishment (FE) in Poland
• EU One Stop Shop (OSS) transactions
• Import One Stop Shop (IOSS) transactions
• Toll receipts
• Railway tickets

When should I generate e-invoices in Poland?

e-Invoicing goes live in Poland w.e.f 1 July 2024.

How can foreign companies comply with e-invoicing in Poland?

A foreign entity with a Polish Tax Identification Number (NIP) can generate e-invoices through a proxy.

Poland e-invoicing portal

Who is the e-invoicing portal in Poland?

The government appointed Krajowy System e-Faktur (KSeF) as the e-invoicing authority for receiving, issuing and storing structured electronic invoices.

What is KSeF?

KSeF is the e-invoicing platform in Poland. It is also called the National e-Invoice System. It was developed by a firm called “Critical Applications” which was established by the state treasury.

How does KSeF validate the e-invoice?

The system will validate the compliance of the XML file structure with the logical template of e-invoices in the XSD format and the authorisations to use KSeF. It will not check for factual correctness of the data but will check for structural correctness only.

Has KSeF undergone a security audit?

Yes, KSeF has passed a security audit.

Poland e-invoicing process

Do I need to sign an invoice while sending it for authorisation?

Digital signatures are not mandatory on invoices sent to KSeF, but digital authentication is required when logging into the KSeF portal. It is to establish whether the person logging in on behalf of a company has required permissions to do so. 

Which date is considered an invoice date?

The date when the e-invoice enters and gets accepted in the KSeF system is considered the invoice date.

Do I need to send the invoice to KSeF whenever it is issued?

It is not mandatory to send the invoice to KSeF whenever it is generated. However, you should submit the same before the 15th day from the end of the month you’ve made the taxable supply.

Suppose you sold goods on 7 August 2023; you should issue the invoice by 15 September.

Shall I mention the KSeF identifying number on the invoice printout?

No, it is not mandatory to include the KSeF invoice identification number on the invoice printout.

Can I make attachments to the e-invoice?

No, you can not add any attachments to the e-invoices. However, you can add an appropriate link to the content of the invoice.

What could be the major reason for e-invoice rejection?

Invoice rejection can happen mainly due to 

• The submitted e-invoice structure mismatches with the logical formula 
• Submission of e-invoice by an unauthorised person

What happens if an e-invoice sent to KSeF is rejected? 

If the KSeF rejects the invoice, the sender shall prepare it again with the correct details and resend it.

Can I download the e-invoice in bulk?

Yes, it is possible to download invoices in bulk, but only in XML form.

Can I issue more than one corrective invoice for a sales e-invoice?

Yes, you can issue any number of corrective invoices for one sales invoice.

Can a rejected invoice be cancelled or corrected?

The invoice rejected by KSeF is considered as not issued. Hence, the sender cannot send the corrective invoice or cancel the same.

Can I issue a proforma invoice through KSeF?

Poland Value Added Tax (VAT) Act won’t consider the proforma invoice as an invoice. Hence, you can not issue such documents through KSeF.

Can I do self-invoicing under Poland e-invoicing?

Yes, a seller authorising the buyer to self-invoice must grant the buyer this right in KSeF.

Can we send approved invoices to buyers outside of KSeF?

Yes, you can do so once KSeF approves it. The format of communication needs to be agreed between buyer and seller. Cleartax can help sellers to send invoices in the required format to their customers.

What if KSeF is down?

You should send the e-invoice to KSeF within seven days after failure. 

Is it required to send the JPK_VAT file to tax authorities if we do E-invoicing?

There is no need to send the JPK_VAT file separately if all your invoices are issued through KSeF.