Poland (2023 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 partnerships. It has been in force since 18 April 2019.

Poland is advancing on the use of B2B electronic invoicing. According to the plans, from July 1, 2024 the Polish Ministry of Finance will mandate an National eInvoicing System (KSeF), which will be a central government platform for the issuance and reception of electronic invoices. Companies must send all electronic invoices to the KSeF, where a digital time stamp will be applied. The goal of this system is to enable the exchange of electronic invoices in the B2B relationship and fit into the CTC monitoring model. In October 2021, a test period began when service providers could participate in system testing with KSeF.  In January 2022, a voluntary phase started, where companies could begin issuing "structured" invoices to KSeF and benefit from fiscal benefits. The Ministry of Finance has conducted extensive public consultations and, via a statement with changes to the KSeF system, Poland aims to postpone the implementation date of the B2B electronic invoicing in the country to July 1, 2024, when the use of B2B electronic "structured" invoice (XML) will be mandatory.

Strategy

National eInvoicing strategy in the medium (2023-2024) and long term (2025-2030)

The Ministry of Finance is working on the implementation of mandatory B2B/B2G eInvoicing from 1 July 2024.

A standard for eInvoices in public procurement has been in place for several years. At the same time, from January 1, 2023, a voluntary system based on the national standard developed by the Ministry of Finance has been in operation. From July 1, 2024, it is planned that the systems will be integrated and that e-invoicing will become mandatory. In the years 2025-2026, the system should operate as a mature one.

Strategy for ensuring cross-border eInvoicing interoperability

Cross-border invoices will be exempt from the national obligation, but they will be still possible to be exchanged electronically, for example using the Peppol network.

Numbers and statistics

At the end of 2022, over 17 000 entities were registered on the platform, including over 16 000 from the public sector. In whole 2022 over 330 000 e-invoices were exchanged via PEF.

Implementation of EN 16931 compliant eInvoices

Approach

Currently B2G eInvoicing  is implemented via Peppol. Ministry of Economic Development and Technology performs the duties of Peppol Authority. The current PEF platform and KSeF platform, which will be available for both B2G and B2B, will be integrated before 1^st of July 2024. It means that the economic operator will be obliged to use KSeF platform to handle B2B invoices and will be free to choose which one platform (PEF or KSeF) to use for handling B2G invoices.

As a consequence, it is planned to use the national standard in the platform to be developed by the Ministry of Finance that will support B2G and B2B eInvocing, in parallel with the PEF platform which will continue to be used.

Uptake of EN 16931

According to the Polish Ministry of Economic Development and Technology, the Directive 2014/55/EU and the introduction of the EN 16931 have moderately contributed to increasing the adoption of eInvoicing.

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).

In addition, from May 2022 it is possible to send invoices for mass services, such as gas, telecommunications or electricity sales - the so-called standard has been made available. a specialized invoice. This standard was developed in accordance with the Extensions methodology and approved by OpenPeppol.

eInvoicing services offered by the government (free of charge)

The new KSeF system is available free of charge for B2B and B2G. In parallel the PEF system based on the Peppol network is available free of charge as well. The Supplier will be free to choose which one standard and system should be used, anyway PEF will be available for B2G only.

PEF system

Issuing eInvoices by Suppliers relay on a voluntary basis, while their reception and acceptance 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. No electronic signature is required for eInvoices.

Benefits at the national level

The implementation of the Directive facilitates operational efficiency and environmental benefits, but research in this area has not been conducted.

Monitoring activities

There is monitoring in place for both the central and sub-central levels. The number of suppliers using PEF and the number of eInvoices that are submitted via PEF are monitored via the administrator’s panel. 

[1] (Compliance updates – Poland, 2023)

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Last updated:  Jul 10, 2023 08:21