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KSeF in an accounting firm: client permissions

How a client grants an accounting firm permissions in KSeF, who can pass them on to the firm’s employees, and when a ZAW-FA notification is needed.

AuthorArtem ShevchenkoFounder and systems architect
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KSeF in an accounting firm: client permissions

Since 1 February 2026 every VAT taxpayer receives invoices through the National e-Invoice System (Krajowy System e-Faktur, KSeF), and since 1 April 2026 smaller businesses issue them there too. For an accounting firm this means one thing: to download a client’s invoices or to issue them on the client’s behalf, the firm needs permissions in KSeF. Without them the invoices sit in the system and the firm keeps asking the client for PDFs.

We write as a small firm that builds custom systems. We know KSeF from our own product, Biurko (biurko.io), in which we built sending invoices to KSeF and fetching them from it. Biurko is a product for small businesses, not software for accounting firms, so what we write below about a system for a firm is a proposal, not a description of a finished implementation.

Who grants the permissions

The client grants the permissions, not the firm. In the standard model the Ministry of Finance lists four kinds of permissions: owner permissions, permissions to manage permissions (this one can be granted only to a natural person), permissions to issue invoices and permissions to access invoices. To the firm as a business (identified by its NIP, the Polish tax identification number) the client grants what the firm needs: access to invoices, issuing, or both.

When granting a permission, the client marks one more thing: whether the firm may pass it on to its own employees. The Ministry calls these indirect permissions (uprawnienia pośrednie). The firm’s employee then gets access to the invoices of selected clients, or of all the clients who have authorised the firm. The firm logs in to KSeF in its own name, not as the client.

Access to invoices, issuing, or both

Which permission to grant the firm depends on what the firm does for the client:

  • Access to invoices lets the firm download the client’s invoices from KSeF without asking the client for PDFs.
  • Issuing invoices lets the firm issue invoices on the client’s behalf.
  • Both permissions are needed when the firm both downloads the client’s invoices and issues them for the client.

That is where the scope ends. The firm does not receive from the client the permission to manage the client’s permissions, and it can pass on to its employees only what it received itself, and only if the client allowed it. So for each client it is worth recording two things: which permission the client granted and whether the client agreed to indirect permissions.

Issuing on a client’s behalf is also a matter of deadlines. From 1 January 2027 penalties apply for an invoice issued outside KSeF contrary to the obligation, so if the firm issues invoices on the client’s behalf, it is worth having the issuing permission granted in advance, not on the day of the first invoice.

When ZAW-FA is needed

A company that is not a natural person and has no qualified electronic seal starts with a ZAW-FA notification. In it the company names one natural person, who then grants permissions electronically, including to the firm. Since 1 February 2026 the ZAW-FA(3) form has been in force; it can be filed on paper or electronically, but not through ePUAP (the electronic platform of Polish public administration). A company with a qualified electronic seal does not need ZAW-FA.

So ZAW-FA does not apply to every client. Before the firm starts waiting for permissions, it is worth knowing which of three situations the client is in:

  • The client is a natural person. The client does not file ZAW-FA and grants the permissions to the firm themselves.
  • The client is not a natural person but has a qualified electronic seal. The client does not need ZAW-FA.
  • The client is not a natural person and has no qualified electronic seal. The client first files ZAW-FA(3) and names one natural person in it. That person then grants the permissions to the firm.

In the third case it is worth recording whom the client named in ZAW-FA. That is usually the person the firm will ask for a permission when a new one is needed, for example for issuing invoices alongside access to them.

What this means for the firm

With several dozen clients, permissions become a separate list to keep track of: who has already granted access, who needs a reminder, which employee serves which company. Accounting software usually does not show this. In the system we will build for your firm, such a list can live next to the client’s documents: you can see for whom fetching invoices from KSeF works and for whom a permission still has to be granted.

In such a system the firm authenticates in KSeF in its own name, and the system can fetch the invoices of every client who has granted access and assign them to that client’s company. Roles can mirror the division in KSeF: an accountant sees in the system the clients they serve. If the firm’s accounting software has an API or file import, the fetched invoices can reach it without retyping. The system is meant to complement that software, not replace it.

Checklist for the firm

  1. List your clients and for each one mark which permission the client granted the firm: access to invoices, issuing invoices, or both.
  2. Check whether the client allowed the permission to be passed on to the firm’s employees. If not, employees will not get indirect permissions to that client’s invoices.
  3. For clients who are not natural persons and have no qualified electronic seal, check whether they filed ZAW-FA and record whom they named in it.
  4. Decide which employee serves which company. If an employee does not need the invoices of all clients, give them access only to the invoices of selected ones.
  5. Add KSeF permissions to the things the firm handles at the start of work with a new client, next to the contract and the list of documents.
  6. Agree with the client who on their side is responsible for KSeF permissions and whom the firm should turn to when something needs to change.
  7. Before closing the month, check for which clients fetching invoices from KSeF does not work, so that the gap is not discovered on the last day.

The description is based on Ministry of Finance documents: the KSeF 2.0 Handbook and module II of the “Środy z KSeF” (“KSeF Wednesdays”) training sessions on granting permissions (links below). For an unusual client situation it is worth checking the details at the source.

If you want to see what this could look like for you, describe your process.

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