The introduction of the National Electronic Invoicing System has two main goals – tightening the tax system in Poland and improving the turnover of invoices in business and accounting. In order for entrepreneurs and accountants to truly benefit from these changes, they need to be properly prepared for them. That is why, at the first stage, KSeF is a voluntary instrument, and only from July 1, 2024 it will become mandatory for active VAT taxpayers, and from January 1, 2025 – for taxpayers of non-tax payments. Let’s figure out how the implementation of CSEF in accounting should take place in order to improve your work and interaction with clients.

Introduction of KSEF and accounting rights

When starting to work with the National Electronic Invoice System, special attention should be paid to the issue of authorization. This is the most important aspect that makes KSeF possible.

In accordance with Article 2(1) of the Regulation of the Minister of Finance on the use of the National System of Electronic Accounts, the following types of permits are distinguished:

  • granting, changing or revoking rights to use the National Electronic Invoicing System is the right of so-called management in KSeF of “users” in a given company;
  • Issuing or accessing structured invoices is an authority that allows you to manage or check sales in a given company (if only the ability to access invoices is provided, i.e. downloading sales and purchase invoices from KSeF);
  • issuing structured invoices within the framework of self-invoicing is a permission that allows you to manage sales in a given company within the framework of self-invoicing.

It is important to note that an individual entrepreneur has so-called owner rights, i.e., without performing additional actions, he has the broadest rights in KSeF for his company. He can log into KSeF by authorizing himself with a trusted signature (ePUAP) or qualified electronic signature, and use KSeF, as well as manage the rights of other entities in his company.

If the taxpayer is not an individual, but, for example, a limited liability company that has an electronic qualified seal containing an INN, then it can use the KSEF on the basis of its original ownership rights without submitting additional notifications to the tax office. If the organization does not have such a seal, then in order to be able to use KSeF, a ZAW-FA notification must be submitted to the tax office indicating the individual authorized to use KSeF on behalf of the company.

Questions and answers on KSeF – interview at the Ministry of Finance

Concerns about delegating authority to issue and access structured invoices to the accounting department or to specific accounting employees were clarified in a Treasury Q&A.

Question 1: If invoices are issued on my behalf by the accounting department, do I have to authorize individual members of the accounting department to issue invoices each time?

Answer: The KSEF provides for the possibility for the taxpayer to indicate an organization authorized to issue invoices, for example, an accounting department. In this case, taxpayer invoices can be issued by individuals authorized to issue invoices on behalf of that organization, i.e. employees of this organization.

Question 2: Can I list non-employees, such as the accounting department, as those authorized to issue invoices on my behalf, or must I list the accounting department?

Answer: Under the KSeF, the taxpayer has the choice of either directly granting authority to specific individuals, including those outside his organization, or designating an entity authorized to issue and/or receive invoices and allowing indirect delegation.