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Not in KSeF: documents from outside the system

KSeF does not collect all of a client’s documents. Which invoices and vouchers an accounting firm still receives as a PDF or a photo, and why there are more of them during the transitional period.

AuthorArtem ShevchenkoFounder and systems architect
  • 7 min read
Not in KSeF: documents from outside the system

KSeF, the National e-Invoice System (Krajowy System e-Faktur), has changed the route invoices take between Polish companies, but it has not taken the collecting of documents off the firm’s hands. In a 2026 wFirma survey, 91.5% of 515 accounting firms answered that after KSeF arrived they had to change how they organise their work. On top of that come documents that are simply not in KSeF.

Below we gather them in one place, together with the provisions of the VAT Act where they matter, and at the end we give a checklist for the firm.

Invoices from sellers abroad

The VAT Act exempts from issuing invoices in KSeF, among others, a seller who has neither a seat of business nor a fixed establishment in Poland (Art. 106ga(2), point 1), and also one whose fixed establishment in Poland does not take part in the sale (point 2). An invoice for advertising, software or hosting from a foreign company still arrives by email or sits waiting for download in the supplier’s panel.

This exception, however, has limits. A seller from abroad whose fixed establishment in Poland takes part in the sale must issue invoices in KSeF. Other sellers from abroad may do so voluntarily (Art. 106ga(4)). So some foreign invoices may arrive through KSeF, which is why, before the firm asks the client for them, it is worth checking what is already in the system.

Sellers from other European Union countries referred to in Art. 113a are also exempt from issuing invoices in KSeF (Art. 106ga(2), point 6). This is not about Polish companies exempt from VAT under Art. 113: they have no separate exception in KSeF and no separate deadline.

Invoices for private individuals and the OSS procedures

An invoice for a natural person who does not run a business does not have to go into KSeF (Art. 106ga(2), point 4) — the seller may issue it there, but does not have to. Invoices under the OSS and IOSS procedures (the EU VAT One Stop Shop and Import One Stop Shop schemes) also stay outside KSeF (point 3).

This is about the client’s sales, not the client’s costs. If the client sells to private individuals or under the OSS or IOSS procedures, some of the client’s sales invoices may not be in KSeF. The firm then needs to know where to get the rest: from the program in which the client issues invoices, or directly from the client.

The transitional period: the limit and receipts

While the transitional period under Art. 145m lasts, a company may still issue invoices outside KSeF if their total in a month does not exceed the limit set there; from the invoice that exceeds the limit, KSeF is mandatory. During the transitional period under Art. 145n, invoices from a cash register and receipts with a NIP (the Polish tax identification number) that count as invoices may also remain outside KSeF. So the firm’s client may keep receiving some cost invoices as PDFs.

This is a transitional solution. From 1 January 2027 penalties apply for an invoice issued outside KSeF contrary to the obligation, and the KSeF number becomes mandatory in payments under the split payment mechanism.

Receipts, contracts, statements

An ordinary receipt (without the buyer’s NIP) is not an invoice, so it does not go into KSeF. Contracts, bank statements, payroll lists and HR documents do not either. The client still has to deliver all of this to the firm.

The KSeF deadlines do not change this part of the work: these documents are not invoices, so they will not reach KSeF after the transitional period either. They often arrive by email, messenger, as a photo from a phone or in a binder, and before the bookkeeping starts someone has to sort them.

Two document channels for one client

In practice every client of the firm now has two document channels. The first is invoices in KSeF: the firm downloads them itself, on permissions granted by the client, and does not have to ask for them. The second is everything we described above: foreign invoices, sales outside KSeF, receipts, contracts, statements and HR documents. This channel cannot be downloaded from any register, because the client has to send the documents.

If KSeF permissions work, the month’s gaps mostly concern the second channel. Accounting software handles bookkeeping well, but it does not collect documents from clients and does not remind them about gaps, so this work often ends in emails, phone calls and spreadsheets.

Checklist for the firm

  1. Every month check both channels separately: whether the client’s invoices were downloaded from KSeF and whether the client sent the documents from outside KSeF.
  2. Ask the client about foreign suppliers, for example of advertising, software or hosting, and agree who downloads their invoices from the suppliers’ panels every month.
  3. Before you ask the client for a foreign invoice, check whether the supplier issued it in KSeF.
  4. Find out whether the client sells to private individuals or under the OSS or IOSS procedures and where the invoices that are not in KSeF are.
  5. While the transitional period lasts (Art. 145m and 145n), also ask about cost invoices in PDF from Polish suppliers and about receipts with a NIP.
  6. Collect receipts without a NIP, contracts, bank statements, payroll lists and HR documents as before: KSeF will not replace them.
  7. Agree with the client on one channel for documents from outside KSeF instead of email, messenger and binder at once.

How not to retype it by hand

In a system that we can build for your firm, the client uploads such documents in a portal (a photo from a phone or a PDF), AI reads the data from them, and the accountant checks the reading next to the original and approves it. AI can make mistakes, so the final say stays with a person. The system fetches invoices from KSeF separately, on permissions granted to the firm. Sending and fetching invoices from KSeF, reading documents with AI and data from GUS (Statistics Poland) we have already built in our own product, Biurko.

Biurko is a product for small businesses, not software for accounting firms. We show it as proof that we already have these elements built and working. A system for a firm can include:

  • a list of the month’s gaps, which the client sees in the portal;
  • email reminders on the days the firm sets;
  • checking a Polish counterparty in GUS and the bank account number on the VAT white list (biała lista podatników VAT);
  • an exchange rate from NBP (the National Bank of Poland) next to a foreign invoice;
  • passing approved data to the accounting software through an API or a file, without replacing that software.

This is a proposal, not a description of a finished implementation. We agree the scope with the firm at a free consultation, starting from what its accounting software accepts.

See what we build for accounting firms.

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