How do you turn compliance from a burden into an operational advantage? That was the core theme of our recent webinar featuring (guest) Forrester Senior Analyst Meng Liu, alongside Comarch’s own Kamila Kania and Jakub Krawczyk.

While the live session covered the macro trends, the audience chat was buzzing with specific, on-the-ground queries about implementation. We rounded up the best questions we missed live to provide you with this "part two" of our discussion, covering the nitty-gritty of credentials, timelines, and third-party integrations.

Regional Deep Dives
(UAE, France, Poland, Japan, Slovakia)

What VAT credentials need to be verified in the UAE, and how does a company handle this?

To verify credentials such as the VAT TRN and legal name, a company must first select an Accredited Service Provider via the EmaraTax portal for their specific Tax Identification Number (TIN).

The user is then redirected (with an AuthCode) to the Provider’s site to confirm their TIN. The Provider validates this data via the FTA API. Once verified, the TIN becomes the Peppol Endpoint ID and is officially linked to that Provider in the Central Register.

What specific VAT credentials must be verified in France to support compliant e-invoicing?

To ensure compliance in France, platforms must perform several key checks:

  • SIREN Verification: Verify the Seller and Buyer SIREN against the PPF directory to confirm active VAT status.
  • Consistency Checks: Ensure the SIRET is consistent with the SIREN.
  • Intra-Community VAT: Validate numbers, particularly for VAT groups.
  • Exemption Codes: Check for specific codes like "VATEX-FR-FRANCHISE" for franchise regimes.
  • Note: Because multiple edge cases exist, we recommend approaching this implementation with a full understanding of the underlying business processes.

Is the e-invoicing obligation in Poland definitely starting in 2026? Has it not been postponed?

The dates are set. The government has confirmed that mandatory e-invoicing via KSeF will move forward starting February 1, 2026, for large taxpayers (turnover > PLN 200m) and April 1, 2026, for all other taxpayers.

Is there a risk that the KSeF system in Poland won't work properly at launch? If so, what is the backup plan?

Technical complexities, particularly regarding "Offline Modes" and potential system overload, are recognized risks. To mitigate this, the regulations allow businesses to issue invoices in offline mode, provided they are submitted to KSeF by the next business day. This acts as a safety valve for business continuity.

Could you elaborate on the current e-invoicing status in Japan?

Since 2023, Japan has utilized the Qualified Invoice System (QIS). While e-invoicing isn't strictly mandatory yet, it is strongly encouraged via the JP PINT (Peppol-based) format. However, full mandatory requirements for qualified invoices are expected to come into effect by January 1, 2027.

Will Comarch be acting as an authorized digital courier in Slovakia?

Yes, Comarch is currently applying for accredited service provider status in Slovakia. We aim to ensure full readiness before the proposed January 1, 2027 mandatory deadline for domestic B2B transactions.

Business Process & Technology

Status monitoring is key for e-invoicing. From a process perspective, what are the main opportunities here?

Real-time visibility allows you to spot and fix data errors immediately, which significantly reduces processing cycles. Effective status tracking gives you total control from the moment an invoice is issued, ensuring every transaction is fully traceable and compliant.

What AI/ML services are available to users of Comarch portals?

We leverage AI for several critical functions: automated document classification, anomaly detection, fraud detection, and predictive analytics. Additionally, our Machine Learning models accelerate document translation across various global formats to ensure error-free processing.

How can a third party, like a factoring company, receive e-invoices?

Assuming this refers to the Poland KSeF mandate, the primary legal exchange is between the seller and buyer. However, factoring companies can be integrated as authorized third parties in three ways:

  1. Authorized Access: The seller grants the factor formal "viewing permissions" within the national portal to download validated invoices.
  2. The "Podmiot3" Field: The seller enters the factor's Tax ID in the specific "Podmiot3" data field, automatically making the invoice visible to the factor in the government system.
  3. Parallel Provider Flow: Using a provider like Comarch, the system "splits" the path. The legal XML goes to the national portal, while a digital copy is simultaneously sent to the factoring company.

How can an Enterprise Legal Management solution be incorporated into these models to track spend and legal info?

Comarch acts as the "single source of truth." Once an invoice (e.g., from a law firm) is validated by a national portal like KSeF or Peppol, our platform pushes that clean, structured data directly to the ELM system.

The ELM then uses that data to perform "compliance audits" against your legal contracts—automatically checking if billed rates or expense types match your master agreements before the invoice is released to finance for payment.

How does e-invoicing affect T&E? Is a hotel stay paid with a business card considered a B2B transaction?

Yes. In countries with mandates, B2B hotel and T&E transactions are shifting from "personal reimbursement" to "direct corporate billing."

  • The Shift: In mandates like Poland’s KSeF, a hotel invoice is only tax-deductible if issued directly to the company’s Tax ID (NIP), not the individual.
  • The Process: Hotels must issue a structured e-invoice via the national portal at checkout. The employee often receives no paper document, as the "legal original" goes directly to the employer's digital inbox.
  • The Requirement: Hotel staff must capture full corporate billing details at check-in to ensure the XML routes correctly.

What happens if a hotel provides the invoice after checkout? How does this affect the flow?

Late invoicing creates a disconnect between the traveler and the data, as well as a VAT timing risk.

If a stay ends on the 31st but the hotel transmits the invoice on the 1st, the tax deduction may be pushed to a different period. Furthermore, you cannot simply fix mistakes at the front desk; the hotel must issue a formal corrective e-invoice through the national system, adding significant administrative friction.

Strategy & Timeline

What if we don't become compliant on time? What are the consequences?

If your systems aren't ready when a mandate (like KSeF) goes live, the consequences are immediate:

  • Financial Penalties: Tax authorities generally impose high fines for non-compliance.
  • Invalid Invoices: If an invoice isn't issued/received via the official platform, it is legally "not an invoice." Buyers may refuse to pay because they cannot claim the VAT deduction.
  • Cash Flow Stoppage: Without compliance, you literally cannot issue a legal invoice, stopping your cash inflow. You also won't be able to "read" incoming supplier invoices, damaging vendor relationships.

How late is "too late" to start preparations? Is there a standard timeline for compliance?

To keep it brief: for a large organization, starting less than 6 months before a mandate is the "risk zone."

At that stage, you are fighting the clock and competing for a limited pool of technical experts. Compliance begins with a deep data assessment—before you even call a provider.

Once that foundation is set, a typical implementation with a provider like Comarch takes 2 to 3 months for configuration and testing alone. For global groups with multiple ERPs, that timeline naturally extends much further.

Global e-invoicing regulations are becoming increasingly complex. If you are managing invoicing across multiple borders, you need the full picture.

Download our "E-Invoicing Policies Around The World" eBook to get a detailed breakdown of mandates, timelines, and technical requirements for over 50 countries.

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