June 2024

Mandatory Electronic Invoicing Postponed

The pervasive influence of digitisation is reshaping tax systems on a global scale. From a European perspective, Poland introduced a voluntary national e-invoicing system at the beginning of 2022, allowing taxpayers to issue so-called structured invoices. The invoicing system was meant to become mandatory across the country effective 01 July 2024; however, Poland’s Ministry of Finance has announced a surprising postponement of this obligation.

Fighting Fraud

The system’s goal was for structured invoices to be issued, shared, and stored in XML format according to a strictly defined template and technical requirements. The main objective was to prevent VAT fraud by centralising the process of registering invoices in business transactions.

The plan was for the system to be mandatory for registered VAT taxpayers with a registered office or a fixed establishment in Poland (although there are several exceptions to this). Invoices issued to individuals not conducting business activities (B2C transactions) were to be exempt from using the system.

Preparing to Implement

Seeing that the implementation of the system would be both time-consuming and costly, companies were told that they could use both commercial software or free programs and applications provided by the Ministry of Finance to integrate with the new e-invoicing system. The Ministry of Finance even provided dedicated test software to facilitate implementation. These steps were taken to give businesses enough time to adequately prepare for this revolutionary change.

With companies gearing up to implement the system beginning 1 July 2024, a bombshell came when the Ministry of Finance announced at the beginning of January 2024 that the deadline for the mandatory e-invoicing system would be postponed, and the system would not, in fact, enter into force this year. The detection of a host of critical errors prompted this decision, as these errors would have prevented the effective implementation of the system by the planned date and threatened the stability of business operations across the country.

Hope is not Lost

On 26 April 2024, the Finance Ministry announced a new effective date for the National e-Invoicing System. The launch of the system is to take place in two stages: from 1 February 2026, mandatory invoicing will cover companies with a turnover of more than PLN 200 million a year, and from 1 April 2026, all other companies.

Originally published by GGI.

For more information, contact Head of Tax Piotr Prokocki.