Mandatory e-invoicing in Poland (KSeF) – becomes fully obligatory in Poland as of 1 April

As of 1 April, Poland has officially introduced mandatory use of the National e-Invoicing System (KSeF) for all VAT taxpayers. The reform marks a major shift in the way invoices are issued and processed in Poland, and is expected to have significant practical implications for both domestic and foreign businesses operating in the Polish VAT system.

While the full operational details of KSeF are complex, several key rules are particularly relevant for international groups and non-resident entities:

Foreign businesses with a Polish VAT presence (fixed establishment)

Companies established outside Poland but holding a Polish VAT number and having a fixed establishment in Poland will be required to use KSeF for issuing invoices related to their Polish VAT activities. This includes foreign entities that are VAT-registered in Poland due to local operations.

Cross-border transactions issued by Polish VAT taxpayers

Polish VAT-registered businesses must issue invoices via KSeF even where the underlying transaction is cross-border in nature, including exports of goods and intra-Community supplies (ICS). This means that even purely international transactions may fall within the mandatory KSeF framework from a Polish compliance perspective.

Limited access for foreign counterparties

KSeF is a domestic system, and foreign business partners will not have direct access to it. As a result, although invoices must be generated and stored in KSeF, they will need to be transmitted to non-Polish recipients through alternative channels, such as PDF (mail) or other agreed commercial formats.

Invoices from foreign counterparties

Invoices received from foreign entities (i.e. those not holding a Polish tax identification number (NIP) and not having a registered seat in Poland), for example in connection with imported services, are not subject to the obligation of being registered in the KSeF system.

Overall, the introduction of KSeF represents a fundamental transformation of the VAT compliance landscape in Poland, with a particularly strong impact on cross-border business structures and foreign VAT-registered entities. Given its broad scope and technical complexity, the reform requires careful assessment of existing invoicing and reporting processes within international groups. The practical implications will continue to evolve as administrative practice develops. Should you have any questions or identify Poland-related VAT matters within your client portfolio, we would be pleased to assist.Dół formularza