“First Goods, Then Invoice” — How to Account for It in PKPiR?

📌 What the Regulation Says (Paragraph 9)

When goods intended for commercial resale—and documented by an invoice—are delivered before the invoice is received, taxpayers must:

• Prepare a detailed internal description of the goods upon delivery.
• Record the purchase in the PKPiR based on this description.
• Later, link the invoice to that description once it arrives. [archiwum.rp.pl], [gofin.pl]

🗓️ Which Date Counts?

The Ministry emphasizes that, when booking the purchase in PKPiR, taxpayers should use:

• The invoice issue date, not the date when the internal description was created. [archiwum.rp.pl]

This reflects the official tax authority’s position: regardless of when the description was made, the invoice date determines the accounting date.

✍️ What the Description Must Include

According to longstanding PKPiR rules (prior to 2026), the internal document should cover:

• Supplier’s name and address
• Quantity and type of goods
• Unit price and total value
• Signature and date by the person receiving the goods
• Be retained and later matched with the actual invoice
• If the invoice later differs in value, the difference must be recorded on invoice receipt [gofin.pl]

Additionally, if the supplier-provided delivery note (specification) already contains that data, no separate internal description is needed. [gofin.pl]

🧾 How to Make the PKPiR Entry

When entering the purchase:

• Use the invoice date in the PKPiR’s date column (column 2) as the date of the economic event. [gofin.pl], [rachunkowosc.com.pl]
• The entry is based on either the internal description or the invoice itself, depending on which comes first.

✅ Bottom Line for Accounting Practice

• Describe immediately when goods arrive without an invoice.
• Record in PKPiR based on that description, but use the invoice issuance date for the record.
• Attach the invoice later and record any price differences at that time, if applicable.

This aligns with the Ministry’s interpretation of Paragraph 9 of the new PKPiR regulation, reinforcing that regardless of when descriptive documentation is made, the invoice date governs the accounting entry.

Sources:

• Ministry disclosures in the Eureka system (entries 670629, 671795) via Rzeczpospolita [archiwum.rp.pl]
• Pre-2026 PKPiR rules on goods received before invoice (official commentary via Gofin) [gofin.pl]