E-INVOICING IN POLAND

Update 8 May 2024

Only a few months before the original deadline (July 2024) for mandatory B2B and B2G e-invoicving in Poland, the Polish authorities has, due to critical errors, decided to postpone the implementation of the new mandate in Poland until 2026.

The new dates are:

1 February 2024	B2G and B2B e-invoicing will be mandatory for all Polish companies with an annual turnover of more than 200M Polish Zloty.
1 April 2026	B2G and B2B e-invoicing will be mandatory for all Polish companies.

ACHIEVING COMPLIANCE IN POLAND: AN OVERVIEW WITH MYSUPPLY

In Poland, since 2019, they have been using the PeF platform (Platformy Elektronicznego Fakturowania), which focuses on e-invoicing for the public sector. This platform will soon be replaced by a centralized platform called KSeF (Krajowy System e-Faktur), where B2B invoices will become mandatory.

LEGISLATION

• Poland’s robust B2G e-invoicing legislation is based on EU Directive 2014/55/EU, which requires all Polish public organizations to be able to receive electronic invoices.
• Furthermore, mandatory B2B invoicing through KSeF will be introduced, meaning that all Polish suppliers must invoice their Polish private customers through the KSeF platform, and all Polish companies must receive e-invoices/credit notes via the KSeF platform.
• E-Invoicing will also be mandatory for foreign companies with a permanent establishment in Poland.

WHAT CAN BE EXCHANGED?

Electronic Invoice and Credit Note: Peppol BIS Billing 3.0 Invoice & CreditNote is used.

Electronic Invoice and Credit Note: A Polish XML format defined as FA(2) is utilized.

Electronic Corrective Invoice: A Polish XML format defined as FA(2) corrective Invoice is used to rectify any previously sent invoices

HOW ARE ELECTRONIC BUSINESS DOCUMENTS EXCHANGED?

KSeF Platform: The KSeF central invoice platform for B2B e-invoicing. EDI service providers integrate with the KSeF platform to send and receive electronic FA(2) XML files on behalf of the Polish companies they serve. The integration between KSeF and the EDI service provider occurs via an API integration. It is the responsibility of the EDI provider to ensure that the integration complies with the standards defined by the Polish government and that the format sent and received is compliant with Polish legislation.

PeF Platform/Peppol Network: The central platform used for B2G e-invoicing in Poland. Here, the Peppol network can be used to invoice Polish public organizations.

TAX REPORTING / TAX CLEARANCE

SAF-T: Poland has introduced a SAF-T (Standard Audit File) for submitting VAT information to the Polish tax authorities. The SAF-T file must be submitted monthly.

CTC and VAT Reporting: When the Polish KSeF platform becomes mandatory, the Polish government will receive invoice data that can serve as the basis for checking for any potential VAT fraud, as all necessary information will be included in the electronic invoice.

ARCHIVING REQUIREMENT

5 years for e-invoices in general.

KSeF retains invoice data for 10 years.