Mandatory e-invoicing from 2024

The National e-Invoicing System (NeIS) allows issuing and sharing structured invoices. Structured invoices (e-invoices) are currently available through the National e-Invoicing System to volunteers on par with the other invoices: hard copy invoices and electronic invoices. 

According to the decision of the European Commission (EC), the NeIS should be mandatory only for entities having a registered office in Poland. It is not clear whether the NeIS will be mandatory for foreign VAT-registered taxable persons that only have a fixed establishment in Poland. A bill implementing mandatory e-invoices in Poland, as presented by the Ministry of Finance in December 2022, says that such taxable persons will also have to use structured invoices. If such provisions are introduced, they will be non-compliant with the EC decision. 

The legislative bill has gone through the stage of public consultations and is currently at the review stage. According to the information provided by the MF, despite numerous critical comments, the bill still envisages that the NeIS will be mandatory for entities that have a fixed establishment in Poland. A new bill will be most probably put forward in February. 

Additionally, the Ministry of Finance is planning to disallow invoicing using a cash register. The amendment is to enter into force at the beginning of 2025, that is, some time after the mandatory structured invoicing goes live. 

Sending and receiving invoices in structured form will require taking technical preparatory measures and integrating the existing systems, so as to ensure that invoicing is done in a structured and automated way. Additionally, enterprises will have to develop internal processes for e.g. invoice verification, document workflow monitoring and delivery of invoices to those who do not have to use the NeIS. Adaptation to the new requirements will involve many people: IT specialists, accountants and tax advisers. Well implemented changes can have a positive impact on the organisation of processes, automation and standardisation within companies. 

It is worth getting ready in advance for the introduction of the obligatory National e-Invoicing System, as this will help avoid possible missteps in the future. We recommend that you review your contracts, accounting processes, procedure manuals and workflows.

Rödl & Partner's experts offer comprehensive support in implementation of e-invoices: from review of the company's existing accounting system, to the choice of technical approach to the implementation of e-invoices, to the actual implementation. 

If you are interested in further information or support in preparation for the implementation of the National e-Invoicing System, you are welcome to contact our experts.