e-Invoicing in Poland
Electronic invoicing in Poland is built around a mandatory clearance model controlled by the tax authority. Below is a high-level overview of how it works.
Actors involved
- Issuer (Supplier): The business that creates the invoice.
- KSeF (Krajowy System e-Faktur): The central platform managed Ministerstwo Finansóv and podatki.gov.pl. This is the mandatory hub that validates, receives, and routes invoices in Poland.
- Recipient (Customer): It can be B2B (another Polish business), or B2G (a Public Administration entity).
- Service Providers: Optional platforms that perform transmission to/from KSeF on behalf of the issuer or recipient.
Core process flow (clearance model) in ExFlow E-Invoicing with Pagero integration
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Invoice creation: The supplier generates the invoice in XML format using ExFlow Document Integration and send it via Pagero.
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Transmission to KSeF: The XML is digitally signed and uploaded to KSeF by Pagero.
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Validation: KSeF runs a technical and fiscal compliance check, including XML format validity, structural correctness, VAT numbers, required fields and cross-checks.
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Acceptance or Rejection: If errors are found, KSeF rejects the invoice and returns an error message. The message is retrived by ExFlow Document Integration and exposed to the user. The supplier user must correct and resend. In case of acceptance, KSeF provides to the supplier a string that proves the invoice has been approved. Supplier must store this string and the URL that comes with it.
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Delivery to Recipient: Once validated, KSeF makes the invoice available to the recipient.
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Storage and archiving: Both parties must preserve electronic invoices digitally according to Polish fiscal archiving rules. KSeF stores the invoices for 10 years.
Legal and technical prerequisites
- Assure your Pagero account contains all necessary data and certificates/tokens to connect successfully to KSeF, ExFlow AP is 2.18.0 or newer and that ExFlow Document Integration is version 1.3.1 or newer and it is completely setup to work with Pagero integration.
- Make sure the legal entity is configured for using the CTC flows going to: ExFlow document integration / Setup / Parameters / General, in CTC and clearance fasttab select "CTC flow" = true.
The invoice xml generation is done using Microsoft D365 Finance Electronic Reporting technology and thefore this feature must be enabled in the environment and legal entity.
Limitations
Currently, Truvio provides Electronic Reporting configurations for:
- Sales and Free Text Invoices.
- Sales and Free Text Credit Notes.
If the legal entity is posting Project invoices or Project Credit Notes, the necessary files must be obtained from Microsoft ("Project e-invoice (PL)"). These ER Configurations will output FA3 format for project invoices that can be sent to Pagero for processing.
Truvio currently supports full end-2-end AR & AP flows for Sales Invoices and Corrective Invoices for Sales Order invoices, Free text invoices and Project invoices. Advance and offline invoices are not supported.
Clarify internal tax data
Ensure you know for the Polish entity:
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Tax registration number (NIP).
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Required exempt reason codes and legal reasons in case non standard VAT is used.
For customers:
- Their NIP.
Common D365 Finance localization & master data
Import the Truvio provided ER Configurations and assure they are correctly setup and all required parent ER Configuration are available.
Go to Accounts receivable - Setup - Accounts receivable parameters, Electronic documents tab:
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Set the Electronic document source / ER format for:
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Sales and Free Text invoices,
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Sales and Free Text credit notes,
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Project invoices and credit notes (future release).
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This tells D365 which ER configuration to use to generate the invoice XML that will be sent to KSeF through Pagero integration.
Legal entity: Polish fiscal data
In the Polish legal entity:
Go to Organization administration - Organizations - Legal entities.
On the Tax registration fast tab, fill in:
- Tax registration number
As mentioned above, make sure that the right coding and legal reason for Sales tax codes are entered. Examples: zero VAT rates, Exempt codes, Reverse charge, etc.
Customer master data: e-invoicing parameters
For each customer subject to e-invoicing, ensure the country and VAT registration status are correct (this drives nature codes, reverse charge use cases, etc., but some of that is also handled via tax codes).
In the customer’s card / Invoice and delivery:
- Tax Exempt Number
To validate that the correct setup is done, it is strongly suggested to post a test invoice(Sandbox or test environment), run the Microsoft delivered "Sales e-invoice (PL)" Electronic Reporting Configuration and upload manually the output file (FA3 format) into the Test or pre-Production KSeF environment. This will validate that the setup and tax coding is correct before posting any invoice in the production environment.