Electronic invoices in Poland mandatory by 2024

Poland takes a step forward on e-invoicing in 2022 introducing The National e-Invoicing System (KSeF) as a voluntary solution and plans to make it mandatory by 2024.

## Update March 2023: the Polish government published some updates on KSeF:

  • General mandate B2B e-invoicing will start by July 2024. However, the implementation deadline for taxpayers benefiting from subjective or objective VAT exemptions will be January 2025.
  • Mandate KSef will not cover B2C invoices. Similarly, invoices issued in OSS and IOSS procedures will also be excluded from KSeF.
  • Penalties shall only be applied from 1 January 2025.

More information here.

## Update February 2023: the mandatory implementation of electronic invoices in Poland will be postponed until July 2024. Find here the official notice. It was postponed, as it was initially planned for January 2023 and later to January 2024. ##

Polish tax authorities are gradually introducing the electronic invoicing requirement in Poland. The National e-Invoicing System (KSeF) will be available for use on a voluntary basis from 1 January 2022. This means that before its mandatory implementation, paper invoices, non-structured electronic invoices and invoices issued via KSeF will be accepted.

This introduction follows the pilot test that tax authorities are conducting at the moment with taxpayers – available from October to December 2021. This pilot is used to allow taxpayers to adapt their IT systems for the National e-Invoicing System, and the information environment uses anonymous data. Invoices issued during the test period do not have any legal effects and will be deleted after some time from the system.

As announced on their website, it is expected that the National e-Invoicing System (KSeF) becomes mandatory by July 2024.

Electronic invoicing are already introduced or planned for the near future by a number of countries in the European Union, such as Italy, Portugal or France.

Poland announces a voluntary implementation of e-invoicing by 2022, and to make it mandatory by 2024. 

How to generate Polish e-Invoices?

The format for electronic invoicing is an XML with the logical structure set by the tax authorities – known as FA_VAT. The draft version if this logic is already available in the tax authorities’ website.

Polish electronic invoices can be issued via the tool published by the Polish tax authority or using commercial programs.

Below you will find a brief overview on the steps for introducing this system:

  1. Businesses will need to first notify the use of KSeF to tax authorities and also their customers.
  2. It will be required that companies create an individual account in the KseF system – which requires certified identification.
  3. Invoices issued are prepared according to the structured logics set by the authorities.
  4. Once ready, invoices issued are sent to the KseF via an interface that enables the exchange of data. KseF verifies the correctness of the invoices and assigns an identification number.

In order to send electronic invoices via KseF, the counterparty on the transaction must agree with this procedure. Otherwise, an alternative must be provided so the recipient can have the relevant invoice as this is a voluntary system for the moment.

What are the advantages of opting for electronic invoicing?

The electronic invoicing introduction brings an important benefit for taxpayers: this is that taxpayers using electronic invoices will receive a VAT refund within 40 days, instead of 60 days if they meet certain requirements. The conditions are the following:

  • The taxpayer opts for the KSeF solution.
  • The taxpayer is registered for VAT during at least the last 12 months – active registration.
  • The taxpayer submitted VAT returns for the last 12 months.
  • The taxpayer has a bank account included on the white list for at least the last 12 months.
  • The amount of VAT refund is not higher than 3,000 PLN.

Certain taxpayers using electronic invoices may receive a VAT refund within 40 days, instead of 60 days if they meet certain requirements.

Also, invoices are stored in KSeF can be consulted in a period of 10 years.

These advantages may encourage some companies to opt for voluntary introduction of KSeF starting 2022.

Who will be subject to Polish e-Invoicing?

  • Companies registered for VAT purposes in Poland.
  • Companies performing activities exempt from VAT.
  • Businesses registered in Poland under the OSS scheme, and with a Poland VAT number.

In view of the above, it is expected that this requirement will affect non-established businesses just registered for VAT in Poland.

Some other clarifications

Polish tax authority clarifies that National e-Invoicing System (KSeF) structure for e-invoices is different than the current structure for the PEF, for electronic invoices in public procurement, concessions for construction works or services and public-private partnership.

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