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KSeF – Does It Matter for VAT-Exempt Taxpayers?

  • Writer: Paweł Gorzelec
    Paweł Gorzelec
  • Oct 23
  • 2 min read

The introduction of Poland’s National e-Invoicing System (KSeF) marks a key milestone in the country’s digital transformation of tax reporting. While KSeF will soon become mandatory for most businesses, many entrepreneurs are wondering – does it also apply to VAT-exempt taxpayers?

The answer: not always – and understanding the exceptions is essential before the new rules take effect.


Who Is Obliged to Use KSeF?

All entrepreneurs with a registered office or fixed establishment in Poland will, in principle, be required to issue and receive invoices via KSeF. However, the VAT Act provides certain exemptions, notably concerning VAT-exempt sales.


VAT Exemptions: Two Main Categories

There are two main types of VAT exemptions in Poland:

  • Subject exemption – based on the value of sales (below PLN 200,000 annually).

  • Object exemption – based on the nature of the activity, e.g., financial, educational, or medical services.

VAT-exempt taxpayers are not required to register as active VAT payers, which directly affects their KSeF obligations.


Must VAT-Exempt Taxpayers Issue e-Invoices?

In general – no.

The law excludes only one specific case from KSeF: financial services. However, VAT-exempt taxpayers can decide whether they want to issue invoices at all.

If they choose not to issue invoices, they do not need to use KSeF.If a buyer requests an invoice, the taxpayer must issue it – as long as the request is made within three months of the month in which the sale or payment occurred.


Sales to Private Individuals

When selling to private consumers, even if a buyer asks for an invoice, the seller is not obliged to use KSeF. The invoice can be provided in paper or electronic form, as agreed with the buyer.


Receiving Invoices in KSeF

VAT-exempt taxpayers with a tax identification number (NIP) can access and download invoices from KSeF.

If the taxpayer does not have a NIP, they cannot log into the system. In this case, the seller must share the invoice outside KSeF, including a QR code for verification and identification.


Temporary Exemption for Micro-Entrepreneurs

Between April 1 and December 31, 2026, VAT-exempt micro-entrepreneurs are temporarily exempt from KSeF obligations if their total monthly sales documented by invoices do not exceed PLN 10,000.

Exceeding this threshold triggers the obligation to use KSeF.


Summary

KSeF will not always be mandatory for VAT-exempt taxpayers, but understanding its principles can help entrepreneurs prepare for the transition. Voluntary use of the system may simplify invoicing processes and strengthen cooperation with business partners.



 
 
 

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