Transactions documented outside KSeF
It is important to note that while e-invoicing obligations in Poland come into effect in July 2024, the Polish national e-invoicing system, the Krajowy System e-Factur, has been a live, functioning environment as far back as January 2022. While Kofax is awaiting the Polish Ministry of Finance’s final technical specifications, we do not expect major revisions to the KSeF framework which is currently functional.
That having been said, there will be specific points that still need to be clarified by the Polish Ministry of Finance. This includes the position around QR codes, which are currently envisaged to be present on every PDF or visualisation of the XML file.
Another key consideration includes which transactions can be documented outside the KSeF environment. Presently, it is expected that tickets that function as invoices - such as plane, railway and ship tickets, amongst others- do not need to be issued via KSeF in a structured form, in accordance with the draft legislation.
The Polish Ministry of Finance has also opened a new public consultation to help ascertain which supplies should be excluded from the scope of the e-invoicing regime.
Kofax is awaiting final technical documentation to confirm the exact scope of transactions which can be issued outside KSeF, therefore precluding these transactions from any penalties if they are not issued in a structured form.