Poland (2021 eInvoicing Country Sheet)

Legislation

The law transposing the eInvoicing Directive (2014/55/EU) was introduced in November 2018 as the Act of November 9, 2018 on electronic invoicing in public procurement, concessions for construction works or services and public-private partnership. It is being in force since 18 April 2019.

eInvoicing platform and eInvoicing management solutions

eInvoicing in Poland is the subject of the responsibility of the Ministry of Economic Development, Labour and Technology and the Łukasiewicz Research Network – Institute of Logistics and Warehousing. Poland completed the implementation of the eInvoicing Directive by the building of a platform on electronic invoicing in public procurement (PEF) to process and exchange eInvoices. PEF is the central platform used by public entities and economic operators for B2G eInvoicing in public procurement.

The platform supports the sending and receiving of eInvoices, orders and additional documents in a standardized XML format such as dispatch advice, receipt advice, correcting invoices and accounting notes. The platform consists of two Peppol Access Points implemented by service providers. The two service providers were selected through the tender procedure that finished in Q2 2018.

The implementation of PEF services has been divided into three stages. The first stage of the project was the selection of the future PEPPOL Access Point service providers - PEF Brokers. In Q4 2018, the first functionalities of PEF, eInvoicing and eOrdering went live. Finally, the project was completed in Q2 2019 delivering full PEF functionalities (including DesAdv, RecAdv and reporting) to public and private users. Accompanying works related to the promotion of the project and training were conducted for the last three years also.

Approach for receiving and processing eInvoices

Issuing eInvoices by Suppliers relay on a voluntary basis, while their reception and acceptation by Purchasing Authorities - according to the Directive - is mandatory. All the public authorities have to register their accounts on the PEF platform, thus every invoice for public procurement sent in a structured electronic standard must be transmitted through PEF. Economic operators can also use the platform which is free of charge, but they can also decide to use other market solutions that work within Peppol network.

eInvoicing implementation in sub-central level contracting authorities 

Poland has a centralized platform in place used by more than 15K registered contracting authorities. The central platform is based on the Peppol network. Every registered public entity can receive eInvoices from other network users, as long as eInvoice is EN-16931 and Peppol BIS Billing 3.0 compliant. There is no difference between central and sub-central entities. From 18 April 2019, all sub-central entities have to register their profiles on the platform and be prepared to receive and process eInvoices also. The European standard is considered unique in public procurement and is fully implemented.

Peppol CIUS – BIS Billing 3.0 is used as national CIUS (no substantial difference against Peppol, but specification complemented by Polish business terms definitions and interpretations). Poland uses an extension to the European standard on eInvoicing (regarding correcting invoices - specific for the Polish tax system). The communication concerning the CIUS goes through a website dedicated to eInvoicing in Poland. It is a knowledge base for all domestic stakeholders of the process, including information about CIUS used. In addition, during the period 2016 - 2019, a series of meetings, webinars and workshops were conducted to raise awareness of how the platform PEF works. Some of the promotional actions, webinars and training are continued according to needs and available resources.

The main identified benefits of the implementation of eInvoicing at the sub-central level are cost and operational savings, the reduction of administrative burden and optimization of time to payments and the facilitation of cross-border eInvoicing.

On-boarding activities at the sub-central level and SMEs are handled through meetings with representatives of public administration were organized (e.g. webinars, training). In the first half of 2019, a large media campaign was also carried out (before the platform was launched).

Status on the implementation of the European Standard on eInvoicing (EN)

The European Standard on eInvoicing in Poland was implemented through the use of Peppol BIS Billing 3.0 as the basic specification of eInvoices in public procurement (mandatory on the PEF platform). A guide to implementing this specification in Polish conditions has been developed. Similar implementation guides were prepared for the remaining post-award documents (Order, DesAdv, RecAdv, Correcting Invoices, Accounting Notes).

The project of law was adopted in September by the Council of Ministers and was sent to the Polish Parliament on 22 November 2018. The final wording of the Act was adopted by Polish Parliament and signed by the President. The legislative work on the implementation of the provisions of the Directive has been completed.

Monitoring eInvoicing implementation 

There is monitoring in place for both the central and sub-central levels. There are reports from the central platform (PEPPOL) of which the Ministry is the administrator. It evaluates the number of suppliers using eInvoicing and the number of eInvoices that are submitted. 

The total number of public procurement in Poland for 2018 was approximately 155 000 and on average there were about 2.2 offers per procurement. At the end of 2020, over 16 000 entities were registered on the platform, including almost 15 000 from the public sector. At the same time, almost 100 000 Post-Award electronic documents were exchanged using PEF, mostly eInvoices (over 97% of all documents).

Use of Core Invoicing Usage Specifications (CIUS) at national level

Poland did not create its own CIUS but has been using the Peppol BIS. Polish specifications are covered by the Peppol BIS Billing 3.0 specification (and other Peppol BIS specifications). Therefore, due to the specific requirements of Polish law regarding correcting invoice, its specification was developed and published in compliance with the Peppol BIS Billing 3.0 semantic model and its syntax.

Poland - specifically, the Ministry of Economic Development, Labour and Technology - acts as a Peppol Authority.

One of the main challenges now is to prepare additional extensions for specific “sectoral” requirements such as telecommunication, energy or gas. This way Poland intends to involve large companies (especially in the utility sector) in the eInvoicing process, as the current European Standard is not adequate and sufficient for them.

A series of workshops with leading companies in utility sectors (telecom, gas, water and waste) as well as factoring were conducted to gather the specific sectoral information requirements. These requirements were then analyzed and pertinent extensions to the core part of the EN invoice will be proposed to these sectoral markets.

Additional information

Aside from the implementation of the European standard on eInvoicing based on Peppol BIS, the PEF project provides complementary services, such as education and PEF promotion dedicated to public and private stakeholders. It targets also the Polish IT sector, especially application and service providers as one of the most important building blocks of the Polish eInvoicing framework.

The use of structured eInvoices in Poland is low. The main reason of it is a voluntary B2G eInvoicing for the economic operators (no obligation for issuing the EN invoice for public procurement). Nevertheless, one of the main goals of the developed platform is to encourage issuers to handle eInvoices.

The platform is free of charge for contracting authorities and suppliers to support the exchange of eInvoices between both actors. The platform will only allow the exchange of EN conformant eInvoices – using Peppol eDelivery Network and Access Points. End-users will be able to use an eInvoicing platform as well via web and desktop applications as via their software, thanks to the simple API interface, that was successfully prepared.

The Polish OpenPeppol office managed by the Ministry and handled by the Łukasiewicz Research Network – Institute of Logistics and Warehousing has been operating in Poland since November 2019. The office provides support in on-boarding new Peppol service providers, serving current members, managing specifications for documents and other issues.

According to the plans of the Polish Ministry of Finance, the launch of the National eInvoicing System (KSeF) is planned in the coming years. The goal of this system is to enable the exchange of electronic invoices in the B2B relationship and fit into the CTC monitoring model. Work on this system is currently in the concept phase.

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Last updated:  Jun 29, 2021 10:48