Poland: News on KSeF from MoF Pre-Consultation

Marta Sowińska
July 19, 2024

Yesterday, 18 July 2024, the Polish Ministry of Finance (MoF) held a pre-consultation with businesses and other stakeholders regarding potential changes to the upcoming e-invoicing system, KSeF. The main consultations are going to take place from September 2024.

The discussions covered 3 topic areas: 1) B2C e-invoices 2) additional postponements and sanctions 3) issuance of e-invoices outside of KSeF in a paper format.

The highlights of the discussion were as follows:

  • New schema FA(3): the MoF plans to introduce changes to the schema with the new version FA(3). Potential changes brought up cover JST/payment date.
  • B2C e-invoicing: the expansion of the mandate’s scope will likely include B2C transactions. Discussions were also held as to whether it should be introduced on a mandatory or voluntary basis.
  • Offline mode: the proposal to maintain the offline mode as a voluntary option during the transition period was discussed. This would allow e-invoices to be issued outside of KSeF with a QR code and sent to KSeF the next business day.
  • Paper invoices: the possibility of issuing invoices outside of KSeF by taxpayers for whom implementing KSeF might be problematic was raised, as well as the applicable thresholds.

Next steps: the MoF announced plans to undertake certain actions from September 2024:

  • Publication of the draft schema FA (3) for the public consultation and draft schema for the structured attachment.
  • Publication of the new draft Act with proposed changes to KSeF.
  • Publication of the Roadmap regarding alignment on the KSeF PROD, TEST, and DEMO environments, to eliminate the differences between the environments and facilitate the implementation processes for the taxpayers.

This discussion was held as part of a pre-consultation session. Therefore, before any regulatory actions are taken and enforced, the proposed topics and possible changes will be further examined during the next consultation, planned to take place in September.

The link to the official news and the presentation from the pre-consultation is available here.

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Author

Marta Sowińska

Marta Sowińska is a Junior Regulatory Counsel at Sovos. Based in Lisbon and originally from Poland, Marta earned a Bachelor’s degree in International and European Law from the Hague University of Applied Sciences in the Netherlands and has studied at the Beijing Normal University in China.
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