How to implement KSeF? 7 key points

December 4, 2023

Even though the National e-Invoices Register in Poland (KSeF) is to become the obligatory tool for sharing invoices starting only from July 1st 2024, many entrepreneurs are already getting ready for the implementation of this tool. This is a very rational approach as sending and receiving invoices via KSeF will not only require readiness on the part of financial and accounting teams but very often it will also require the need to introduce changes in almost all departments operating in a given organisation. How should KSeF be implemented? There is not just one answer that can be given to this question that would be correct for all entrepreneurs.

How to implement KSeF?

In the article below we will discuss what key factors we will have to consider when implementing KSeF. We highlight however that these are not all the factors that we should be analysing. Ultimately, the scope of changes that need to be implemented to start using KSeF will depend among others on: the nature of the business and its scale, invoicing programs and systems, as well as the processes operating in a given organization.

1. Verification of the circulation of purchase invoices and the process of issuing sales invoices

Every entrepreneur has their own developed processes for the circulation of purchase invoices and methods of issuing sales invoices. Before starting the implementation of KSeF a specific “inventory” of each invoice process should be made. In the instance of purchase invoices, it should be verified among others: who has access to invoice documents and the circulation of these invoices in the company (e.g. for payment acceptance). In the instance of sales invoices, it should be checked which departments are currently responsible for this process and make a decision on whether after the implementation of KSeF, these same employees are to continue to issue invoices.

It is also important to note that by the assumptions adopted by the Ministry of Finance, an invoice is deemed to be issued only at the moment it has been sent to KSeF. This may in turn affect the way data is recognized in the accounting books.

2. Access to KSeF/authorisation

Access to the KSeF system both in terms of providing sales invoices and downloading purchase invoices issued to us, is one of the key factors that we should be analysed in the process of implementation. We will have to decide how many employees will have access to KSeF and also what authorisations will be issued to them. There are many solutions in this regard. The two most popular ones are:

  • making use of an authorisation token;
  • the purchase of an electronic seal.

Authorisation token

An authorisation token is a free tool developed by the Ministry of Finance which enables the automatisation of the use of KSeF. Automatic connection with KSeF is possible thanks to the token.

Electronic seal

An electronic seal is a type of digital signature through which an entire organisation can be authorised and not just one person. All authorised users can log onto KSeF by the use of an electronic seal. In this instance, the scope of persons who will be entitled to use this seal should be carefully analysed.

3. Integration with KSeF

Integration of the taxpayer’s already functioning systems is maybe one of the most important factors in KSeF implementation. Integration should be considered for both sales invoices (here it seems to be an obvious solution) and purchase invoices (it is not so crucial here, but it can help improve many processes operating in a given company). In the case of entrepreneurs who only use one accounting and operating system integration seems simple. However, in the case of taxpayers who use multiple systems in their business, it is necessary to analyse if all currently used methods of issuing and sending invoices will continue to function after the entry of KSeF. Maybe – to simplify integration – you should decide on operational changes regarding the circulation of invoices.

It is also important to note that KSeF will allow for the downloading of invoices issued to us in the form of a collective file. If our accounting program allows for this functionality, this file will enable the automatic transfer of data to accounting systems. This, in turn, may be an opportunity to improve accounting processes.

4. Visualisation of invoices

Another area that needs to be analysed is the visualisation of invoices off of KSeF. If we would wish to send invoices to our clients or contractors off of KSeF we have to remember that the documents must:

  • correspond to the logical structure provided for invoices in KSeF
  • and be additionally marked with a QR verification code.

5. Failure modes/KSeF unavailability

The Ministry of Finance implementing the regulations that apply to KSeF regulated in great detail issues related to the unavailability of KSeF, whether due to system failure or maintenance. It should be considered how, in this kind of situation, the process of invoice circulation will look. The regulations for KSeF allow for the issuance and sending of invoices in case of KSeF failure or unavailability (e.g. via e-mail). However, it is important to note that the moment the system is restored, it will be necessary to submit the documents generated in this way to KSeF. For this situation, it is worth developing internal procedures and verifying the capabilities of accounting programs.

6. Invoice attachments

Per the assumptions adopted by the Ministry of Finance, the KSeF system will serve to circulate only invoices to our contractors. If at the current moment, we send our clients or contractors any kind of attachments with our invoices (e.g. confirmation of service completion, reports on hours worked), we will have to determine how these documents will be transferred after the entry of KSeF.

7. Payments

While implementing KSeF it Is important to remember the changes that will need to be implemented in the processes and system handling invoice payments. Per the expectations of the Ministry of Finance an entrepreneur making payments for invoices issued through KSeF will have to indicate the invoice number assigned in KSeF in the transfer message. It is also important to remember that the number issued in KSeF is of a length of 35 characters. That’s why we will also have to verify if we can input that much information in the transfer message.

Obligation to indicate the number assigned to a given invoice in KSeF should also be considered in terms of verification of settlements with the contractor. If they are going to be providing the number issued by KSeF in the transfer message, then it will be this number that will be required to verify, if we have received the payment.

More about KSeF

We encourage you to read the entire series of articles about the National e-Invoice Register in the series: “All about KSeF”:

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