The introduction of the national electronic invoicing system (KSeF) from 2026 has changed the procedure for issuing invoices, including in the form of self-invoicing, where invoices are issued by buyers with the seller’s authorisation. The specifics of generating such invoices in the KSeF system are outlined below.

Self-invoicing allows the buyer to issue invoices on behalf of the seller. An organisation purchasing goods or services from a taxpayer may issue invoices confirming sales on behalf of and at the request of that taxpayer. The National Electronic Invoicing System (KSeF) enables this procedure to be carried out electronically.

For such invoicing, an agreement must be concluded whereby the buyer issues invoices on behalf of and at the request of the seller. This agreement also sets out the rules for issuing and approving invoices.

These rules can be implemented in several models, taking into account the granting and delegation of powers. The buyer may issue both original and corrective invoices, or the buyer issues the original invoices and the seller issues the corrective invoices.

The contract must specify the procedure for the taxpayer to approve individual invoices. Approval may be active, involving the review of and comments on the invoice file, or passive, where the failure to provide comments within a specified period, for example within one day, is deemed to constitute approval.

Various forms of authorisation for self-invoicing in KSeF may also be used: direct authorisations or authorisations allowing the seller to appoint authorised persons on the buyer’s side for such self-invoicing.

The invoice issued as part of self-invoicing must specify:

• seller details (section ‘Entity 1’),
• buyer details (section ‘Entity 2’),
• the invoice contains the value ‘1’ in field P_17 and includes, amongst other things, the phrase ‘self-invoicing’.

Invoices issued by the buyer under the self-invoicing procedure will be stored in KSeF for both the buyer and the seller. The buyer will only have access to the seller’s invoices issued by the seller under the self-billing agreement, as well as to invoices issued by the seller on the buyer’s behalf. The buyer will not have access to any other invoices relating to the seller’s sales.

Basis: art. 106d ustawy z dnia 11.03.2024 r. o podatku od towarów i usług.