The Polish government has presented a new set of legal solutions with the objective of providing taxpayers with the requisite tools to implement and utilise the KSeF. It is anticipated that this project will receive the necessary authorisation by the end of 2024.
In addition to the mandatory use of KSeF, the new solutions include:
- Delaying the following requirements until 31 July 2026:
- Providing the KSeF number for electronic invoice payments.
- Additional deferrals for invoices issued from cash registers.
- Deferrals for penalties related to non-compliance with KSeF obligations.
- All taxpayers should be able to use an offline mode until the end of 2026.
- Invoices should be regulated so they can be issued via the KSeF.
- There should be a period until 30 September 2026 for taxpayers with a low volume of invoices to continue issuing them in the traditional format.
- Legal solutions should work seamlessly in the KSeF environment.
When will e-invoicing become mandatory in Poland?
In order to ensure the widespread adoption of e-invoicing in Poland, the government has set a timetable to facilitate its implementation. The following deadlines have been set:
- January 2022: Voluntary phase begins, allowing companies to issue structured invoices through KSeF and receive tax benefits
- The scheduled launch of e-invoicing in Poland was set for July 2024. However, the Ministry of Finance has decided to postpone this to February 2026. At this point, the use of e-invoicing will be mandatory for all companies with a turnover of over €46 million. For all other companies, the obligation will start on 1 April.
The public consultations on the launch of the KSeF began during the summer of 2024 and will conclude in November of the following year. During this period, a roadmap detailing the new FA scheme (3), the draft legislation, and the final specifications of the KSeF has been established through consensus.
Conversely, the Polish Ministry of Finance has elected to reduce the pace of the e-invoicing testing environment due to technical complications and a considerable volume of demand. In practice, the number of test file uploads has been restricted to 10 MB and 100 per minute.
It is anticipated that structured invoices will coexist with paper invoices and the other electronic invoices that are already in operation on the Polish market for the foreseeable future. The acceptance of structured invoices via KSeF is contingent upon the recipient's consent.
In 2020, e-invoicing in Poland was implemented in all public administrations in compliance with the European Directive 2014/55/EU on e-invoicing in public procurement in Member States.
Recognising the significant benefits for private companies and public administrations, the Polish government presented a comprehensive plan for the widespread adoption of e-invoicing in the private sector in 2021.
What e-invoicing model will Poland adopt?
Similar to models in Spain and France, Poland requires real-time authorisation by the tax authority for invoices to be valid. As a result, the National eInvoicing System (KSeF) was set up as a centralised platform where companies submit their invoices. The operational process includes:
- E-invoices are issued in a structured format following the model of the Ministry of Finance.
- Once issued, invoices are transferred from the financial system to the central database (KSeF) via an API.
- Validated invoices are accessible and downloadable by recipients within the system.
- The platform issues confirmations on invoice numbers, rejections or unavailability of KSeF.
UBL 2.1 (XML) is the mandatory format for electronic transmission and receipt of invoices.
Multicountry e-Invoicing
For companies operating in multiple countries, compliance with international obligations can be achieved through a global e-invoicing solution that is certified in all relevant countries.
The SERES multi-country e-invoicing solution offers several benefits, including:
- Adhere to legal and technical requirements in each country, ensuring compliance.
- Streamline workflows between subsidiaries or companies in different countries, making it easier to share information.
- Real-time visibility of subsidiary information, enabling efficient management of treasury, receivables and payables.
- Access to a global operator, eliminating the need for each subsidiary to adapt to different providers and providing support throughout the activation process.
Would you like to learn more about e-invoicing in Poland?
