On March 21st, the Polish Minister of Finance (MoF) held an in-person meeting to summarize the results of the public consultation that took place between February and March. The MoF has announced the following updates:
- Timeline: While a new timeline has not yet been defined, the MoF clarified that all taxpayers, regardless of VAT status, will be required to comply with the KSeF e-invoicing mandate simultaneously. Initially, VAT-exempt taxpayers were expected to be included six months after VAT active taxpayers. Furthermore, a transition period will be implemented, during which penalties and the obligation to include unique ID/batch ID on payments will not apply. Additionally, invoices issued by cash registers were expected to no longer be considered as valid invoices in 2025. The MoF clarified that this consequence will be postponed to an undefined date.
- Scope: The issuance of B2C invoices through KSeF is expected to be permitted on a voluntary basis. Such invoices will incorporate a QR code allowing customers to access them anonymously in KSeF.
- Offline mode: Taxpayers will be able to issue e-invoices outside of KSeF with a QR code, in the transition period, and subsequently transmitting them to KSeF on the following working day.
- Attachments to invoices: A new schema enabling attachments to structured invoices is set to be introduced. This update is expected to impact, among others, suppliers of utilities and telecommunication services.
- QR codes: certificates that are used to generate QR codes used in the offline modes, will be able to be generated from KSeF already in the voluntary phase.
Paper invoices: The so-called digitally excluded taxpayers will be allowed to issue paper invoices when the volume and value of issued invoices are small (up to 450 PLN per invoice and 10,000 PLN monthly). - Legislation: The MoF plans to share a first amended draft act on April 3rd. However, the final rollout date of mandatory e-invoicing is expected to be decided between April and May.
- Further consultations: The MoF plans to conduct a public consultation on the draft act in April and provide training for businesses in May 2024.
In addition to the changes impacting the issuance of e-invoices through KSeF, the MoF has announced the postponement of updates on the JPK with the declaration (the Polish VAT return). Initially anticipated to be implemented from July 1st, 2024, the new date will be announced simultaneously with the new rollout date for KSeF.
More information is available here.
The presentation from the meeting with the MoF is available here.
