Report on the first consultative meetings regarding KSeF Exorigo-Upos among participants

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Report on the first consultative meetings regarding KSeF Exorigo-Upos among participants

On Friday, February 16, 2024, the first two meetings of the consultation cycle on KSeF took place. Our representative, Paweł Pustelnik, was among dozens of experts who had the opportunity to participate in discussions at the Ministry of Finance headquarters. Due to limited seating, meeting participation was also available online – totalling over 1000 participants.

Plan of Action for KSeF

As declared today by the representatives of the Ministry of Finance, in mid-March, a project of legislative solutions for consultation will be presented to everyone.

Between May and April, we are to know the deadline for the mandatory implementation of KSeF. Currently, explanatory meetings on various issues are ongoing, and Exorigo-Upos has received confirmation to participate physically at the Ministry’s headquarters in all meetings.

The cycle’s first two meetings- Security and Efficiency and Consumer Invoices/Buyer Status – are already behind us. The next ones are scheduled for February 21, 22, 29, and March 1. Issues to be discussed include:

  • The KSeF identifier in payments.
  • Access to invoices by factors.
  • They are issuing invoices in KSeF by media suppliers and at gas stations, including the possibility of providing their visualization upon customer request.

Subsequent meetings will involve consultations to discuss issues related to invoicing by local government units, the scope of rights in KSeF and detailed elements of invoices issued in KSeF. A separate meeting will address the implementation of KSeF in stages, considering the potential differentiation of implementation deadlines for specific solutions.

At the end, discussions will be planned to understand entrepreneurs’ expectations regarding materials related to KSeF. The Ministry intends to discuss the participation rules for MF experts in meetings, conferences, and training organized by external entities.

There was also a reminder about the Q&A section on the MF website, where you can find important information. 

At the same time, they emphasized that the project is not starting from scratch, so feedback, not new assumptions, is being collected. (e-mail:

Security and Efficiency

During the first meeting, they discussed issues related to system security. Regarding performance concerns, the Ministry assured that the current environment is test-based, and entirely different parameters will be in place for production.

The tokens are to expire by the end of the year, and instead, certificates should be ready for retrieval by mid-year. In the second half of March, a list of changes to KSeF will be specified, along with the provision of regulations and specifications regarding authorizing certificates.

Certificates utilizing asymmetric cryptography, a global standard, are deemed safer by MF experts than tokens. The level of private keys used by all will allow for individual adjustments to varying security levels, depending on each company’s decision.

The issue of scam invoices was also addressed. If a business receives such an invoice, it can be hidden to avoid disrupting the list of legitimate invoices. Simultaneously, it should be reported – an option will be available. The administration will then verify it. After production deployment, adding functionality to block by NIP number will be explored to combat fraudsters.

In the performance section, Ministry representatives expressed their desire to understand better expectations regarding sending and receiving invoices, with particular attention to distribution across different days and hours. They strongly encouraged sharing such information with them.

Many questions and doubts regarding the emergency mode emerged and required clarification. Regarding the QR code advocated for inclusion, MF will examine the matter due to the significant number of requests from entities that need it.

The Ministry reiterated that it does not plan to provide an SDK for integrators. While a session token will be essential for UPO, in the event of temporary unavailability, there will be an option to retrieve the document.

Many requests from companies and providers revolved around consulting proposed changes in advance. The idea of a consultative group emerged to address this.

Consumer Invoices/Buyer Status

The consultations served to discuss issues related to invoices issued to consumers. Many ideas surfaced on how to approach this matter.

The Ministry conveyed that facilitating the recognition of buyer status requires legislative adjustments and dramatically relies on support in this area from the consultative group. Complications arise, for example, with the NIP (tax identification number), which some individuals possess while others do not, making it currently not a definitive identifier. The issue also involves the accessibility of invoices, for example, using QR codes to ensure consumers can anonymously retrieve them.

There were numerous calls for including B2C invoices in KSeF, which is optional as identifying their distinctiveness for many companies is complex. The solution proposed would be to issue all documents to the government system. However, issuing the invoice in KSeF could become mandatory when providing the NIP.

The first meetings revealed how many topics regarding the system’s assumptions require clarification. They emphasized the importance of involving representatives from companies, integrators, and tax offices at the early stage of consultations for planned changes. The Ministry declared that subsequent modifications would also undergo such verification from a technical standpoint, and proposals for specifications would be released concurrently with subsequent regulation projects.

We warmly encourage directing any questions and concerns to us. Being present and speaking with the Ministry at subsequent meetings allows us to address them on your behalf and strive to obtain answers.

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