Use of structured invoices via the National E-Invoicing System (KSeF) will become mandatory as of 2024, says draft derogation decision of the Council of the European Union.

When monthly SAF-T reporting (in Poland, the Standard Audit File for Tax, or SAF-T, was implemented as JPK) was made mandatory by the Finance Ministry, many companies were not aware of just how revolutionary a change that was in the Polish system for information exchange between business and the National Revenue Administration. The main challenge for businesses was to adjust their financial and accounting systems to comply with the functional requirements of JPK reporting, which turned out to be a costly and time-consuming process. In addition, JPK reporting triggered a number of new duties which were challenging for an average business. There were various complaints, including as to numerous uncertainties about the system and as to technical challenges facing companies during implementation.

Based on the JPK implementation experience, it is prudent not to wait until the last minute to commence introducing solutions that will enable e-invoicing via KSeF.

To prepare for mandatory e-invoicing, taxpayers should first of all ensure they are able to send their invoices to the National E-Invoicing System. This involves modifying invoicing software and/or finance and accounting software to meet the new requirements, potentially with the support of software vendors or IT staff.

It also needs to be remembered that, once you start e-invoicing via KSeF, you will have to take a greater care than before to ensure your invoices are correct in terms of substance. The reason is that the lawmakers’ idea behind KSeF was to allow for real-time reporting of B2B transaction data based on prescribed invoice content, thus permitting the taxman to immediately learn about the transaction and its subject-matter. This in turn serves the purpose of facilitating tax audits and improving the quality of their results, enabling access to data in an easily analysable format, and increasing audit automation.


For those reasons, it seems advisable to ensure that company personnel responsible for financial and accounting compliance are trained to operate in the KSeF environment. A new division of roles and responsibilities within the firm may also potentially prove to be necessary.

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