Structured E-invoices: When and How to Prepare for the Transition to KSeF?

Almost a year has passed since the Ministry of Finance published its plan to introduce a revolutionary change in the circulation of invoices in Poland, presented under the banner of KSeF, i.e., the National System of e-Invoices. Beginning in the Autumn of 2021, the project was finally enacted as an amendment to the VAT Act. Where are we after almost three months from the launch of the volunteer version of KSeF? How can you prepare your company for this change? And when is the best time to switch to the new system, which is to be mandatory for everyone from 2023?

What is KSeF and why is it revolutionary?

The National e-Invoice System is a platform for issuing and sharing structured invoices. Alongside those currently possible, such as electronic or paper invoices, structured invoices are going to be one of the permitted forms of documenting transactions in the initial period of KSeF.

Although the act of 29 October 2021 amending the Act on Goods and Services Tax and certain other acts (Journal of Laws of 2021, item 2076), which introduces KSeF, may at first glance appear inconspicuous (it is only a dozen or so sentences on two pages), it brought a real breakthrough to the Polish legal system. In the same month, tests of the platform started, so that – as announced by the Ministry of Finance – on 1 January 2022 the system would be ready for use.

The proposal of amendments to the act and the shape of the planned regulation, which is to specify the conditions for the launch of KSeF, was published well in advance. It included, among other things, the expected ways of "managing" privileges by the taxpayer in the system.

However, the regulation published on December 30, 2021, and in force (Item 2481) omits the solution from the May proposal, namely – the taxpayer portal has disappeared from it. Nevertheless, it has to be noted that during the latest webinar organized by the Ministry of Finance on April 7, 2022, a Taxpayer KSeF Application was presented – it will allow, among other things, managing privileges and generating tokens. As for now, the application is available in the test environment.

EDI – what is it and how does it solve the KSeF access problem?

Comarch is a leading software provider in the Polish market, including the Comarch EDI (Electronic Data Interchange) platform, which has been enabling the mass transmission of structured documents between business entities around the world for over 20 years. Comarch began working on integration with KSeF many months ago. An important element in this type of solution is experience. Comarch has gained this in recent years by, for example, performing integrations for clients with similar solutions, such as with Sistema di Interscambio in Italy, which the Ministry of Finance referred to in press statements.

Comarch EDI's approach to the new legal realities assumes that all customers currently exchanging e-invoices following the current Polish regulations (via EDI or as PDF invoices) will be able to switch to KSeF in a simplified way, without incurring high investment costs or performing work on internal systems (such as ERP or FK). Every existing and potential Comarch customer who chooses Comarch EDI will be able to communicate via KSeF as an issuer and recipient of invoices. Generating invoices in EDI and integration with KSeF applies equally to the current transmission of invoices already done through Comarch and the transition from communication currently done through other channels, such as by letter or email.

The full range of offers for our customers who want to exchange invoices via KSeF is already presented on the Comarch EDI website, and detailed information will appear there at the beginning of Q2.

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