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Changes to the B2B e-invoicing mandate in Poland following public consultations

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Photo of a workshop organized by the Poland Ministry of Finance in the context of public consultations about the KSeF mandate
Poland KSeF consultations gathered more than 10,000 participants. Photo credit: Poland Ministry of Finance
The Polish Minitry of Finance unveiled key changes to the B2B e-invoicing mandate following public consultations, which gathered more than 10,000 participants.

At the beginning of 2024, the Polish government abruptly stopped the implementation of the B2B e-invoicing mandate.

Following this postponement, the Polish Ministry of Finance organized a series of 9 public consultations to review the implementation of the mandate, which gathered more than 10,000 participants.

Official conclusions were publicly shared by the government on March 21: Official announcement / Summary of the changes. Here are some of the key takeaways.

New timeline to be shared in May 2024

Following the public consultations, the government will draft the necessary amendments to the law by April 3. Subsequent public consultations will then take place in April, leading up to the unveiling of the new timeline at the end of April or beginning of May.

The revised timeline is expected to aim for the implementation of the mandate in 2025 at the earliest, as the government has confirmed anyway that there will be no e-invoicing obligation in 2024.

Additionally, the new timeline will be identical for all companies and all taxpayers, whether they are exempt or not from VAT.

Adjustements targetted towards an easier mandate implementation

Most of the announcements aimed at simplifying the transition to the KSeF platform for companies & taxpayers countrywide:

  • Grace period after the implementation of the KSeF: penalties waived, exemptions for small volumes & amounts, or for some types of simplified invoices (such as ones coming from cash registers)
  • B2C e-invoicing possible via the KSeF platform (but not mandatory): a QR code will allow the consumer to anonymously access his invoice on KSeF
  • Invoice attachments management: for “collective” invoices such as utilities or telecommunications invoices
  • Easier management of “offline” invoices: ability to generate “offline” invoices with QR codes before the mandate deadline, additional day for companies to submit “offline” invoices to the KSeF
  • Shared responsibility between the invoice issuer and a VAT-exempt buyer in determining whether there is an obligation to issue an invoice in KSeF or not

More to come in the next weeks with the publication of the final law on the Poland B2B e-invoicing mandate.

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