Date of invoice issue in KSeF

December 19, 2023

Most entrepreneurs who have begun preparing for the implementation of KSeF have had to deal with the issue that is the “date of invoice issue in KseF”. Why is this so important? More about this in today’s article.

Revolution in invoice dating

For many years entrepreneurs have gotten used to independently indicating the date of issue (sometimes it was “suggested” by their accounting programs) when preparing invoices for their clients.lThe entry of the KseF system will cause a certain revolution in this regard. According to the assumptions adopted by the Ministry of Finance, invoices which we share with our contractor through KseF shall be deemed issued on the day of its submission to KSeF.

The invoice date does not matter

Straight away the question arises: what happens with the date of issue which is currently indicated independently by the entrepreneur? This data will become an element of an invoice shared through KseF, but in principle, it will have no significance and it will have no effect.

The date on the invoice and the date assigned by KSeF may be different

Another question that arises in the scope of the date of invoice issue, is if the date, indicated by the taxpayer and the date indicated by KseF, must be identical. In other words, when issuing an invoice do we have to send it to KSeF on the same day? The Ministry of Finance clearly states that these dates can differ. Thus, we have the answer to the second question – there is no statutory obligation to send an invoice to KSeF on the same day we issue it.

Invoice date in KSeF: example

Concerning the above regulations, there are a few reservations that are worth considering when implementing KSeF:

• According to the assumptions of the Ministry of Finance, an invoice is considered issued only at the moment it is submitted to KseF. So if we issue an invoice on the last day of the month and do not submit it to KSeF on the same day  then, de facto, we should not include such an invoice in the books – such a document is formally not yet considered “issued”.

• Taxpayers, who recognize VAT liability based on the date of invoice issue (e.g. in the case of providing rental services or electricity supply), have to remember that only sending the invoice to KSeF will affect their tax obligations, this is particularly important if invoices are issued in foreign currencies.

Example: On January 31st, we issued an invoice for a rental to our contractor, the invoice is issued in EUR. To convert the VAT amount, we used the exchange rate from January 30. If we send such an invoice to KSeF only on February 5, for example, we will have the wrong EUR/PLN exchange rate.

It is worth noting that the VAT Act provides for certain cases where the date of issue of the invoice indicated by the taxpayer directly in the content of the document will be decisive. An example is the failure or unavailability of KSeF.

Want to know all about KSeF?

Other posts in the series “All about KSeF”:

• How to implement KSeF? 7 important questions
• 5 questions about KSeF
• Unavailability of KSeF
• Will KSeF affect JPK?
• Unavailability of KSeF
• Fixed assets in a company – tax ABC
• KSeF – questions and answers [Part 1]

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