Management of communication with KSeF in a multi-branch company after September 1, 2023.

Planned changes to KSeF for large entities. Find out what entrepreneurs should pay attention to before September 1st based on an analysis of the assumptions of the new regulation.

On August 7, the Ministry of Finance published on the website of the Government Legislation Center a draft amendment to the regulation of the KSeF. The new regulations are to respond to the needs of the market and popularize the use of the system. They will make it possible to grant limited authorizations in the KSeF to large structures of entities with various branches or separate internal units besides the parent unit.

To better adapt it to the specifics of large enterprises, the Ministry of Finance plans to introduce changes to the KSeF. This will allow granting limited authorizations in the system to large entities with, for example, many branches.

What are the changes about?

• The draft amendment to the regulation on KSeF assumes that access to invoices will be possible only within a given branch or other internal unit of the entity, i.e., it will not apply to all structured invoices assigned to this taxpayer (NIP).
• Entities that will be granted the authorization will be able to contribute, change or withdraw approvals to use KSeF by obtaining a unique identifier beforehand. It will contain the taxpayer’s tax identification number (NIP), a string of numerical characters, the entity identifier, and a check digit.

According to the ministry, this solution is a simplification measure and facilitating activities for entrepreneurs. It may be used even before the introduction of the obligation for taxpayers to issue and receive structured invoices via the National System of E-Invoices (KSeF).

The new regulation is to enter into force on September 1, 2023.

What can entrepreneurs do?

Using a unique ID may involve some risk. Everything indicates that the field assigned to it will be used to restrict access. The head office can access the department in the KSeF system but only to invoices with the appropriate unit identifier in the specified field. If the issuer of the invoice provides it elsewhere, e.g. in the comment, the document will not be visible to the authorized entity, which may cause problems in the circulation of documents.

In the face of the proposed changes, two possible courses of action exist.

The first of them – a hybrid, consists of the independent downloading of invoices from KSeF by the branch using the authorized identifier of the unit.

The second option is an independent central hub that processes all invoices from the system, classifies them, and transfers invoices to the appropriate unit.

We recommend avoiding complicated solutions at the beginning of KSeF implementation in the company. First, sending all invoices to the system without involving individual departments will be best. The central hub may control the sent invoices and assign them to the appropriate units. This approach introduces a uniform process in which you can easily control the flow of documents and avoid the risk of double posting a document. If practice shows that exhibitors consistently fill in the identifier field in KSeF, it is possible in the future, change the process so that the branch downloads invoices from KSeF independently.

The changes introduced in the system by the Ministry of Finance are aimed at streamlining the process of issuing and accessing structured invoices.

They can also be modified. The above conclusions are based on the current draft regulation.

We want to remind you that KSeF introduces some changes that may require significant IT processes and systems modifications. Therefore, all invoicing sources should be verified as soon as possible, and then, in consultation with your internal IT department or external service provider, verify that the company is ready to communicate with the government system. We recommend developing procedures for various cases of handling e-Invoices, e.g., lack of attachments.

In addition to the fact that there is a test version of KSEF, for several months, we have been offering our clients the opportunity to use SmartKSeF, i.e., our proprietary communication solution dedicated to the retail industry with the e-Invoice system.

The obligatory KSeF from July 1, 2024, means entrepreneurs have less than a year to prepare for the new changes.

Read more:

Entrepreneur, get ready for KSeF.

SmartKSef – comprehensive service of e-invoices.