Poland: Update on mandatory use of electronic invoices, VAT implications

A draft decision on derogation that would authorize Poland to deploy a mandatory electronic invoicing system

Update on a mandatory electronic invoicing system

The European Commission (EC) on 30 March 2022 submitted to the EU Council a draft decision on derogation that would authorize Poland to deploy a mandatory electronic invoicing system.
The EC action was in response to an August 2021 request from Poland for a departure from the common system for value added tax (VAT) purposes.


Regulations on a new type of invoice—the so-called structured invoice (e-invoice)—were effective 1 January 2022.Currently, issuing invoices under this new system is voluntary. However, beginning in the second quarter of 2023, the use of e-invoices will be mandatory.

A key feature of e-invoices is that they can be issued and sent directly from a taxpayer’s financial and accounting programs in a structured digital form (based on a uniform logical structure provided by the Ministry of Finance), using a system operated by the Ministry of Finance.

  • The taxpayer can issue a structured invoice through an individual account in the KSeF system.
  • Then e-invoices are sent to the KSeF system, and after that, to the recipient, via interface enabling connection and exchange of data between IT systems. Sending invoices to the KSeF system is possible with authentication of the taxpayer in the system with the use of a qualified electronic signature (or an electronic seal in the case of legal entities) or a trusted profile. The date of issuing a positively verified structured invoice is the date the issuer transferred it to the system.

Any taxpayer-authorized entity or individual may issue and access structured invoices in the KSeF system. This means that it is possible to authorize, for instance, an accounting office or specific employees to issue and receive structured invoices on behalf of the taxpayer.

Potential benefits

Use of the KSeF system for e-invoices has certain advantages in terms of VAT settlements, such as:

  • A reduced standard VAT refund period (40 days instead of 60 days)
  • Taxpayers issuing e-invoices via the KSeF system do not have to submit, at the request of the tax authorities, the structure of the standard audit file for invoices
  • Simplifications in terms of settling credit notes
  • Relief from certain record-retention requirements (invoices are stored directly in the system for a period of 10 years)

Read an April 2022 report prepared by the KPMG member firm in Poland


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