Structured invoice data files to be transmitted into the National E-Invoicing System in Poland starting from January 2022

An electronic invoice is a digital file which contains structured invoice data. It will become an optional invoice format in Poland starting from 1 January 2022.  

According to the announcements of the Polish Ministry of Finance, it is also likely that it will become mandatory for all businesses to issue structured invoices starting from the year 2023.

How is it going to look in practice?

First and foremost, the recipient has to give their consent to being issued an e-invoice in the form of a structured file.  

If the recipient does not agree to receiving their invoices through the National E-Invoicing System (KSeF), then it will still be possible to issue invoices in a structured data format, but nevertheless the recipient will have to receive the respective invoices in a format that they will accept (in a digital or paper form).

E-invoices issued in on-premises or cloud-based accounting software will be transmitted to the KSeF via an API.

  • The KSeF will timestamp the invoice and allocate to it a unique ID.
  • The date of invoice transmission to the KSeF will be taken as the date of e-invoice issue, while the date of allocating an ID will be considered to be the date of invoice receipt.

If the recipient does not consent to receiving e-invoices, the existing rules governing the invoice receipt date will apply.

Communication with the KSeF will enable downloading a single invoice or a batch of invoices.

It will be possible to correct an invoice by issuing a structured correction invoice, which will have to contain a reference to the ID allocated by the KSeF to the original invoice.

Correction notes, RR invoices, and proforma invoices will not be recorded in the National E-Invoicing System. The current rules for issuing and receiving those documents will apply.

How can businesses benefit from e-invoicing?

  • Certainty that the counterparty has received the invoice.
  • Guarantee of invoice authenticity, content integrity and readability.
  • Increased efficiency of automated invoice posting due to a unified invoice structure.  
  • No need to issue invoice duplicates.
  • No need to retain invoice documents.
  • No need to hand over invoices to tax authorities.
  • Preferential 40-day VAT refund deadline.
  • Exemption from the duty to sent the JPK-FA single audit file at the request of the tax authorities.

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