Updated in April, 2024

Context 

Like other European countries, one of the main reasons that e-invoicing has been established in Poland is to prevent tax fraud, although this is only the latest of several precautions the country has already taken. As of now, Poland has already implemented monthly VAT reporting, electronic financial analysis, and an online fiscal cash register system for monitoring transactions (in the retail sector). Now, with the introduction of electronic invoicing, Poland will be one step closer to eliminating VAT tax fraud.  
 

B2G E-Invoicing 

B2G e-invoicing is already mandatory in Poland. All public authorities must be able to receive e-invoices via the country’s national e-invoicing platform, the PEF. The PEF is used for B2G e-invoicing between private companies and government entities in public procurement. Public authority suppliers are not required to submit their invoices electronically, but many suppliers opt to do this voluntarily by choosing a service provider that serves as a PEPPOL Access Point, such as SPS Commerce (formerly known as TIE Kinetix). 

The PEF was first introduced in 2019 and since then, all sub-central Polish public entities are required to register on this platform in order to be able to recieve e-invoices. The PEF supports the sending and receiving of e-invoices, as well as other transactional documents in a standardized XML format. The platform consists of two PEPPOL Access Points implemented by service providers. 

B2B E-Invoicing 

In Poland, B2B e-invoicing transactions have been allowed but voluntary since the beginning of 2022 and will only become required as of July of 2024. The EU has granted Poland provisional permission to impose mandatory B2B e-invoicing between January of 2024 and December of 2026. 

On August 7, 2023, the President of Poland signed the Act of June 16, 2023 amending the Polish VAT Act and several other acts. This law confirms the date previously announced by the Ministry of Finance for the introduction of the new e-invoicing format. As of July 1, 2024, taxpayers must be prepared for mandatory electronic invoicing and the National Electronic Invoicing System (KSeF - Krajowy System e-Faktur).

The requirement to send and receive structured e-invoices will not apply to foreign entities in Poland, nor to entities that do not have a permanent establishment but rather are registered purely for VAT purposes in Poland. These taxpayers can continue to issue invoices based on the existing rules (either electronically or in paper form), and voluntary electronic invoicing via KSeF will remain possible for them.  

The Polish Ministry of Finance has published on April 4th, 2024 a summary of the proposed legal options for the revised Polish e-invoicing mandate "KSeF". 

Feedback can be provided until April 19th. 

This formally confirms the likely proposed options originally announced at the meeting, including the mandate applying to all taxpayers in a single wave, as well as specific exemptions and the use of a QR code for invoices issued outside the KSeF. 

Standards 

Poland uses the standard format and PEPPOL BIS Billing 3.0. Given that invoices are compliant with EN16931 and PEPPOL BIS Billing 3.0, all registered Polish public entities should be able to receive electronic invoices from other PEPPOL-connected entities. 

How to process and exchange e-invoices in Poland 

Taxpayers need an ERP system that combines their financial records with the KSeF portal through the PEPPOL-certified API to process and exchange e-invoices in Poland.  

The rules for cash register and fiscal printer invoices are also changing. Cash register invoices can be issued in the current form until December 31, 2024. A fiscal receipt with a TIN will also be recognized as a simplified invoice until the end of 2024.

Importantly, the KSeF does not currently cover, and under the current form of the regulations will not cover, after July 1 (and after December 31, 2024):

  • Consumer (B2C) invoices, 
  • Tickets that function as an invoice
  • and invoices issued in OSS and IOSS procedures.

Conclusion 

In connection with these changes, all companies in Poland will be required to use e-invoicing solutions for their transactions as of July 2024. Until then, e-invoicing is voluntary in Poland, meaning that it can only be used if both supplier and seller agree.  

After this period, e-invoicing will become mandatory in Poland. 

For additional information regarding e-invoicing in Poland, you can find more details here. 

 

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