E-invoicing for b2B and b2c sector in poland

More and more countries take actions and setting up their own system of e-invoicing to help combat VAT fraud and improve the country’s capacity to collect taxes on sales transactions. In Europe there is a regulation for electronic invoicing by Council Directive 2014/55/EU and all EU member states are affected in the long-term.

The Polish Ministry of Finance has published a draft amendment to the Polish VAT act, which introduces structured invoices (a new type of electronic invoice) and the National System of e-Invoices (also called KSeF).

This means that companies using SAP will need to integrate their finance and accounting system and allow invoices to be sent electronically via API, in the appropriate format expected by the Polish Ministry of Finance, to the KSeF system.

It is expected that:

  • From 1 October 2021 transmission of data to KSeF will be voluntary
  • From 1 January 2024 sending e-invoices to KSeF will be obligatory

The complete technical specifications are currently not available for KSeF yet.

You can find details about this draft amendment on the following website: https://legislacja.rcl.gov.pl/projekt/12343202/katalog/12762050#12762050

And the documents which related to the schema of the e-invoice can be found on the following website:


E-invoicing Demo English

E-invoicing Demo Polish

How will the National System of e-Invoices (KSeF) work?

Structured invoices will be issued and received by taxpayers via the KSeF ICT system.
KSeF is an ICT system used for:

  • authentication and verification of rights held by the taxpayer and the entity authorized to access the KSEF
  • notifying the taxpayer or the authorized entity about the rights to issue and access structured invoices,
  • receiving structured invoices,
  • storing these invoices,
  • marking invoices with the identifying number assigned by this system,
  • verify the compliance of the issued structured invoice with the template provided by the Ministry of Finance.


This system will be used to analyze and control the correctness of data from structured invoices. In addition, he will send the following notifications to the taxpayer or the person authorized to issue a structured invoice:

  • the date and time of issuing a structured invoice and the number
  • identifying the structured invoice, assigned by this system,
  • the rejection of a structured invoice – in the event of non-compliance with the pattern of a structured invoice,
  • the inability to issue a structured invoice – in the event of unavailability of the FSC.

Each taxpayer, through an individual account in the KSeF system, will be able to issue an invoice using the template available on the electronic platform of public administration services.


  • VAT refunds will be reduced from 60 days to 40 days.
  • The invoices will be stored in KSeF. In this case not only the taxpayer, but the tax authorities will also have access to the invoices.
  • Relieving taxpayers of the duty to submit SAF-T structures for invoices (JPK_FA) at the request of the tax authorities with respect to structured invoices issued by the taxpayer.
  • The regulations governing issuance of duplicates of invoices will not apply to structured invoices, as it will not be possible for an invoice issued via KSeF to be lost or destroyed.
  • May prove to be the elimination for e-invoices issued in KSeF of the additional documentation requirements introduced for correcting invoices by the SLIM VAT package.


You can find more details about the KSeF on the following link: https://legislacja.rcl.gov.pl/docs//2/12343202/12762044/12762045/dokument487855.doc

Holger Kosboth SAP Lupus Consulting

Directly contact us:

Contact Person: András Boa
Phone: +36306613644
Email: andras.boa@lupusconsulting.com