e-Invoicing mandates and updates: Poland

February 2023

National e-Invoicing mandate postponed to July 2024

The Polish Ministry of Finance have completed a public consultation on new draft legislation surrounding mandatory e-Invoicing via the KSeF platform. The result of the consultation has been to postpone the implementation date of the mandate from 1st January 2024 until 1st July 2024, giving taxpayers a further six months to prepare. Penalties for non-compliance will come into effect as of 1st January 2025.

The draft legislation states that consumer invoices (B2C) will now be fully excluded from the scope of the mandate.

Further, a provision has been made for taxpayers to issue invoices outside of the KSeF platform in the case of technical failure on the taxpayer’s side as long as they are subsequently transmitted to the KSeF system the following day.

The complete statement in Polish can be found on the Ministry of Finance website and the referenced draft act is also available.

Finally, there is a public consultation on a new proposed schema defining the logical structure of e-Invoices. The specifications can be found on the website of the Ministry of Finance.

July 2022

New specifications for e-invoicing mandate released

The Polish e-invoicing is expected in 2024 so companies still have some time to prepare. Here are three important aspects of these new mandates.

Timeline and mode of inception

The Polish mandate imposes a “big bang” approach for both issuance and reception of e-Invoices. After an initial voluntary period, which already came into effect on 1 January 2022, the mandate comes into full force for all companies, regardless of size, beginning in the second quarter of 2023.

The exact inception date of the reform is not yet finalized, which, given the short lead time, is of course going to cause concern for companies operating in Poland. This lack of communication of an official date could lead us to suspect that the Polish system is still not fully ready – but only time will tell.

Ken Clark

Ken Clark is a Director of Product Marketing for OpenText Business Network based in the UK. For over 30 years Ken has been a subject-matter expert in the areas of digital transformation and automation, B2B/EDI/A2A integration, and e-Invoicing and tax compliance. Ken spent much of his career as a hands-on practitioner, consulting on customer problems and implementing business-focused solutions around global supply chain management, order-to-cash and procure-to-pay. Today Ken focuses on solutions for information exchange, B2B and A2A integration, and e-Invoicing.

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