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According to the information provided by the Ministry of Finance, the new date of implementation for KSeF will be announced in late April or early May. Importantly, active VAT taxpayers and VAT-exempt taxable persons will be covered by KSeF on the same date.

The key issues discussed during the meeting with the Ministry are presented below:

  • In the second half of 2024, a KSeF mobile application will be made available to the public.
  • At the beginning of 2024, a series of training sessions will be launched at tax offices throughout Poland, focusing on the following four areas: key assumptions of KSeF, scope of the mandatory use of KSeF, QR codes, and access methods. The Ministry of Finance will provide video tutorials.
  • Meetings with the developers of KSeF tools will be held (in the second half of April). A separate working group for entities issuing high volumes of invoices was also established.
  • From July 2024, a KSeF hotline managed by the National Revenue Administration and a technical support call centre will be operated.
  • On 3 April 2024, the Ministry will present proposals for: legislation (amendments to acts) and interface specifications (including technical information on, among others, self-invoicing by EU entities, buyer's certificate, QR codes, and technical correction of an invoice) for simplified consultations. At the turn of April and May, four draft regulations will be presented. Once the content of the legal acts is approved, preliminary clarifications will also be provided (at the beginning of July).
  • After determining the final content of all documentation for KSeF (including brochures and technical specifications), English-language versions will be developed.
  • There will be a postponement of penalties and of the obligation to provide the KSeF number when making payments (including “MPP” designation), as well as of covering invoices from cash registers and NIP-bearing receipts recognized as invoices with KSeF. The Ministry of Finance will not abandon the collective payment identifier (more information thereon will be provided in the interface specification). The Ministry will not require banks to create a separate field for the KSeF number in transfer/payment orders.
  • During the transitional period (the duration of which has not yet been specified, with 6 months being initially indicated) the possibility to issue "offline" invoices outside KSeF with a QR code and to enter them into KSeF the next business day will be introduced as a universal and unconditional solution. The Ministry of Finance will not verify the reasons for the taxpayer being “offline”, nor will the taxpayers be obliged to provide any documentation explaining it.
  • There will be a possibility to issue B2C invoices in KSeF on a voluntary basis and the principle of "self-identification" of the buyer, to spread the burden between both parties to the transaction, will be introduced (exempt taxpayers will provide their VAT number when registered for VAT, or their NIP [Polish Tax Identification Number] when unregistered). At the same time, the requirement to keep invoices in KSeF for the purposes of tax-deductible costs settlement will be set forth.
  • Proposal for introducing structured invoice attachments, sent to KSeF only by certain industries, was brought about (utilities, telecommunications services and the "other aggregate” category clarified by MF as designed for the fuel industry and encompassing aggregate invoices for fuel). Until works on the attachment are completed, the requirement to provide selected data by entities operating in these industries will be postponed. The Ministry of Finance is open to discussing the use of structured attachments by other industries.
  • Before introduction of the mandatory KSeF, the possibility to create and download buyer’s certificates to invoices issued “offline” and in case of a failure will be made available.
  • It will be permissible for small entities to issue paper VAT invoices during the transitional period (up to the amount of PLN 450/invoice and the sum of PLN 10k per month), but the obligation of additional indication of such invoices in JPK_VAT will be introduced.
  • The regulation bringing amendments to JPK_VAT will be postponed.
  • Integration of KSeF and PEF [Electronic Invoicing Platform] was confirmed and the Ministry has made the relevant documentation available.
  • Customs declarations will be modified to allow attaching invoices issued in "offline" mode. Customs will have access to invoices in KSeF.
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