Reasons for rejection of an invoice by KSeF

According to the plans of the Ministry of Finance, the National e-Invoice System (KSeF) is to become mandatory for all entrepreneurs in Poland on July 1, 2024. The regulations stipulate that each invoice, as soon as it is uploaded to the system, will be considered to have been issued and will automatically enter legal circulation. Is there a risk that KSeF will reject the invoice?

Acceptance of an invoice to KSeF occurs when the system assigns it a unique number. If it is not assigned, it will be tantamount to rejecting the document and considering it as not having been issued. In such a situation, the entrepreneur will be able to remove any errors in the invoice and resubmit it to KSeF. What can be the reasons for rejection of an invoice by the system?

Non-compliance with the logical pattern of an invoice

According to the Law on Value Added Tax, documents sent to KSeF must be in the form of digital structured invoices. These are files in xml format, conforming to the logical structure template published in the Central Repository of Electronic Document Templates (CRWDE) on the ePUAP platform. The system will reject any invoice that does not meet the aforementioned standard or in which all fields required by the regulations - such as the invoice date in the P_1 field or the VAT number in the Entity1/Identification Data field - have not been filled in.

‍

Read more about structured invoice format

Issuance of an invoice by an unauthorized person

Invoices will also be rejected by KSeF if they are sent to the system by an entity that does not have the required rights. Individuals have default access to KSeF (the so-called primary owner rights) . Their authorization in the system is through a trusted or qualified signature, and if the taxpayer does not have them - based on the ZAW-FA notice.

KSeF can also be used by taxpayers who are not natural persons (companies) - in their case, authentication is possible on the basis of a qualified stamp with a VAT number.

The regulations also provide for the possibility of the taxpayer to grant authorization to issue invoices in KSeF to, for example, co-workers, accounting or bookkeeping offices. This can be done in three ways:

‍

• Using commercial programs that enable KSeF, such as Banqup,
• using software developed by the Ministry of Finance,
• via the ZAW-FA notice. An entity authorized to issue accounting documents can do so without having to set up its own account in KSeF. By virtue of the authority obtained, it also has the ability to indirectly transfer them to third parties.

‍KSeFfailure

An invoice may also be rejected by the system due to a system failure. In such a situation, the taxpayer will be able to issue an offline document, using the same structured invoice template that applies during normal use of KSeF. The completed template will be treated as a full-fledged invoice, which will have to be handed over to the buyer.However, the date of issuance of the invoice specified in the P_1 field will be of key importance during the failure. Pursuant to Article 106na (1) of the Value Added Tax Act, if the date of issuance of the invoice is different from the date of its transmissionto KSeF, the invoice will be considered to have been issued at the time of its transmission to the system.

Information on failures and interruptions in access to KSeF will be posted in the Public Information Bulletin of the Minister responsible for public finance. Currently, they can be found on the National Tax Administration website under the "Announcements" tab.