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What do we know after the National e-Invoicing System Consultations?

At the turn of February and March, the Ministry of Finance (hereinafter “MF”) officially concluded consultations with taxpayers on the future fate of the National e-Invoicing System. The following is a summary of the meetings and key conclusions.

Security and efficiency

  • The MF confirmed that issues such as the invoice date and the obligation to mark invoices with a QR code will not change,
  • MF plans to start work on handling invoices issued in foreign languages,
  • The possibility of visualizing invoices in XSLT format and a possible extension of the fallback mode, which now is said to last 7 days after the National e-Invoicing System failure end, are also anticipated,
  • Technical solutions and detailed contingency and functional plans will be published in March,
  • Legislative work on the National e-Invoicing System is expected to be completed in June.

Consumer invoices and buyer status

  • Legislation is underway to establish and verify the status of the buyer. The MF currently envisions verification by means of the TIN number, which would mean shifting responsibility to the buyer,
  • The MF has confirmed that if an invoice is issued outside the system, the seller remains exempt from liability if the buyer has not provided him with a TIN number,
  • The majority of participants favor allowing businesses to issue invoices to consumers.

The National e-Invoicing System ID in payments

  • The MF has confirmed that it will set precise guidelines governing sanctions for failing to include the National e-Invoicing System number in the title of bank transfers,
  • The number of characters in the National e-Invoicing System number, which is currently 35, will not be changed again and is in line with the requirements of the banking sector,
  • The MF has confirmed that the relevant number on the invoice is the National e-Invoicing System number, not the number generated by internal accounting systems,
  • The MF has no plans to create a fallback mode for the bulk identifier, and it will not be possible to generate it online,
  • The payment identifier will also apply to sub-payments,
  • Payments made by a third party are also covered by the mandatory National e-Invoicing System number designation,
  • At this point, it is not possible to download the collective identifier through the API (the National e-Invoicing System program allowing integration with other systems),
  • MF will consider later implementation of mandatory KSeF number in transfer titles.

The National e-Invoicing System in the factoring industry

  • Anonymous access to invoices will require not only a QR code, but also the invoice number, the buyer’s TIN and the total amount owed. These requirements are expected to increase the level of security,
  • External institutions will not be able to access e-Invoices,
  • The MF announced that a set of specifications for QR Codes and Payment IDs will be published on March 18. The English version of the set, on the other hand, will be published after the legislative changes are completed,
  • An entity will have access to an invoice correction, only if the invoice issuer indicates this entity in the Entity3 field,
  • It will not be necessary to provide the entity’s data in the Entity3 field if it was previously entered on the corrected invoice,
  • MF does not plan to inform other entities about the marking of an invoice as false.

The National e-Invoicing System in the media industry

  • Changes to the schema are not foreseen at this point, despite the opinion reported by industry representatives,
  • The MF confirmed that the visualization of the invoice will be in line with the data, but it did not say whether visualizations with more information will be allowed,
  • The MF did not address the issue of invoices in foreign languages.

The National e-Invoicing System in the fuel industry

  • The issue of issuing an invoice at a gas station and possible delays that will force the customer to wait was raised,
  • MF did not indicate what version of the document will be issued to the customer (e.g., visualization),
  • In response to the opinion of industry representatives on the insufficient number of items on the invoice, the MF will take this into account in its possible changes,
  • MF will analyze the possibility of printing invoices using a fiscal cash register, with the understanding that the cash register would work in non-fiscal mode. This means that it would only be used for printing.

The National e-Invoicing System, and Local Government Units

  • Representatives of TSUs pointed out the problem regarding transactions between the Treasury and TSUs and the case where both parties to the transaction have the same representative, which in turn means the same NIP number,
  • The MF proposed modifications to the four-digit identifier, which will make it easier to identify subordinate organizational units (especially in cases where there are many of them),
  • Attention was also drawn to the issue of assigning issued invoices to units when they are not indicated in the Entity3 field, and the lack of a statutory obligation for contractors.

The National e-Invoicing System implementation in stages

  • The topic of providing taxpayers with an invoice mode similar to a fallback was raised. This would mean that the invoice would not be immediately issued in the target format, but for example, in PDF. It would then be transferred to the National e-Invoicing System within a certain timeframe. This way, possible system failures would not introduce the confusion of not being able to invoice,
  • Representatives present at the meeting unanimously expressed the opinion that the most favorable solution for taxpayers would be the introduction of mandatory National e-Invoicing System solutions in two stages: first, mandatory invoicing, then mandatory KSeF number in transfer titles,
  • Most of the representatives present at the meeting expressed the opinion that the National e-Invoicing System should not be implemented as early as January 1, 2025, and a better period would be between Q2 and Q4 of 2025.

Clarifications, interpretations, and training

  • The MF announced that as early as late April/early May, the National e-Invoicing System training sessions will begin for Tax Offices across Poland. Hotlines, webinars, or one-on-one consultations are also planned,
  • The MF confirmed that a campaign is planned to promote the National e-Invoicing System and to reach as many taxpayers as possible.

There is still a lot of work ahead of the Ministry of Finance, but the freshly completed consultation was the first step in connecting with taxpayers and making changes that benefit them. Nexia Advicero specialists will follow the MF’s next steps and keep you updated if there is any new information.