Incorrect KSeF Fraud Reports May Trigger Tax Verification of Suppliers

Summary

A taxpayer who mistakenly identifies a supplier invoice as fraudulent in the KSeF Taxpayer Application may prompt verification activity by the Polish tax administration. The consequences could therefore extend beyond correction of the reporting error and affect the supplier whose invoice was reported.
The issue is relevant to accounts payable, tax and fraud-prevention teams using KSeF reporting functions. An inaccurate notification could expose a legitimate supplier to enquiries and may also disrupt commercial relationships, invoice processing and payment.
Businesses should restrict access to fraud-reporting functionality, require documented verification before submission and establish an escalation route for disputed invoices. If an error occurs, the taxpayer should preserve evidence, notify relevant internal stakeholders and promptly investigate available correction or explanatory procedures.

Article

Businesses preparing for KSeF should pay close attention to the controls surrounding the function that allows users to identify a contractor’s invoice as fraudulent or otherwise suspicious.

According to Gazeta Prawna, an incorrect fraud report made through the Taxpayer Application of the National e-Invoicing System may lead the tax office to undertake verification activities concerning the supplier. A mistaken report can therefore create consequences for a legitimate business even where the reporting taxpayer acted without malicious intent.

The risk may arise from several common situations. A user might fail to recognise a supplier’s legal name, incorrectly conclude that an invoice is duplicated, confuse an authorised intermediary with an unknown issuer, or report an invoice before checking it with procurement or the relevant operational team. Shared-service environments and high-volume automated invoice processing may increase that risk if responsibilities are not clearly assigned.

For the reported supplier, tax verification may involve requests for explanations or supporting documentation. Even if the invoice is ultimately confirmed as genuine, responding can consume management time and create uncertainty. The report may also delay payment while the purchaser conducts additional checks.

Businesses should therefore treat fraud reporting as a controlled compliance action rather than a routine invoice-processing option. Access should be granted only to appropriately trained personnel. Before a report is submitted, designated reviewers should examine the purchase order, goods receipt or service confirmation, supplier master data, contractual documentation and relevant correspondence.

The procedure should distinguish suspected fraud from ordinary invoice discrepancies, such as an incorrect price, purchase-order mismatch or duplicate submission. Those matters will normally require commercial resolution and should not automatically be escalated through a fraud-reporting channel.

Companies should also create an incident process for erroneous reports. This should cover immediate notification to the tax function, preservation of an audit trail, contact with the supplier where appropriate and use of any available KSeF or tax-office procedure to explain the mistake.

As KSeF becomes embedded in daily processing, fraud controls should balance the need to detect false invoices with the need to avoid unnecessary administrative and reputational consequences for legitimate suppliers.

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