Simplified Invoices Do Not Have to Be Issued via KSeF

Summary

• Under Polish VAT rules, an insurance broker must issue an invoice if the customer requests one; if a full invoice is issued, it must be reported via KSeF once the obligation applies. [kpmg.com]
• Simplified invoices are explicitly excluded from the KSeF obligation and do not have to be issued via KSeF, even where invoicing is mandatory. [kpmg.com], [rtcsuite.com]
• Simplified invoices remain allowed until the end of 2026, after which they are expected to be abolished and replaced by standard KSeF invoices. [vatupdate.com]

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Detailed

Under Poland’s mandatory e‑invoicing framework (KSeF), not every invoice requested by a customer must be issued through the national e‑invoicing system. In particular, simplified invoices fall outside the scope of the KSeF obligation, even where a supplier is otherwise required to use the system.

This clarification is especially relevant for insurance brokers and similar service providers, where customers may request an invoice for services rendered.

Obligation to Issue an Invoice upon Customer Request

Under the Polish VAT Act, an insurance broker is required to issue an invoice when the customer explicitly requests one. Where such an invoice contains all standard invoice data required by law, it qualifies as a regular invoice and must, in principle, be issued as a structured invoice via KSeF, once the obligation applies to the supplier. [kpmg.com]

Simplified Invoices: Outside the KSeF System

However, Polish implementing regulations and official explanations confirm that simplified invoices are excluded from the KSeF obligation. These invoices—typically issued for low‑value transactions (up to PLN 450 or EUR 100)—contain a reduced data set and are not supported by the KSeF system. [vatupdate.com]

As a result:

• A supplier does not have to report a simplified invoice via KSeF.
• The fact that a customer requests an invoice does not automatically trigger KSeF, provided the supplier issues a simplified invoice instead.
• This exclusion applies even after KSeF becomes mandatory for the supplier’s category, as simplified invoices are explicitly carved out in the implementing regulations. [kpmg.com]

Practical Impact for Insurance Brokers

For insurance brokers, this means:

• If a customer requests an invoice and the broker issues a full invoice with all mandatory data, that invoice must be issued via KSeF (where the KSeF obligation applies).
• If the broker instead issues a simplified invoice, there is no obligation to use KSeF.
• The choice between a simplified and a standard invoice therefore has direct KSeF implications and should be aligned with internal invoicing policies and system capabilities.

Looking Ahead

It is worth noting that simplified invoices are expected to be abolished in Poland after 2026, as part of the transition to full structured e‑invoicing. Once that happens, all invoices issued to VAT taxpayers will, in principle, have to be issued via KSeF. [vatupdate.com]

Until then, simplified invoices remain a valid and practical exception to the KSeF obligation.

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Simplified Invoices and KSeF: What Changes for Small Businesses After 2026?

• Simplified invoices (for transactions up to 450 PLN or 100 EUR) will be abolished at the end of 2026; until then, structured invoices in KSeF are not required for such sales.
• After 2026, only standard invoices will be allowed, and all sales to VAT taxpayers must be documented in KSeF.
• Simplified invoices require fewer data fields and are currently used for small transactions, but cannot be issued alongside another invoice for the same sale.
• The KSeF system (version 2.0) does not support issuing simplified invoices, indicating a need to transition to standard invoices for all transactions after the new rules take effect.

Source: prawo.pl

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

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