For many entities, KSeF (National Register of e-Invoices) is a revolution in accounting. Is your company ready for this change? How do you prepare for this challenge? Please review the steps we propose to help you prepare for the new e-invoicing process in time.

1. If you haven’t already done so, check out the changes the modified VAT Act introduced. Think about what they mean for your company.
   
2. Identify all sources of sales invoicing and purchase document processing in your company. In the case of capital groups, franchise networks or dispersed structures, ensure not to miss any place, similarly in terms of the B2B, B2C, B2G model, or various sales channels: brick-and-mortar, e-commerce, omnichannel, telesales and others.
   
3. Verify with your IT department or system providers whether a software update is prepared to guarantee communication with KSeF. If such a condition is not met, or for various reasons you do not consider such an option, then an alternative solution is needed to complete the change in the law.
   
4. Check carefully what invoices you issue to customers. Verify the ones you get from your suppliers. In the analysis, consider the type of documents and their content, e.g. what data is exchanged with contractors, whether attachments are used, etc.
   
5. Verify mandatory and optional data availability for the e-invoice structure in the systems issuing VAT documents. Specify the source of information, check the quality and completeness of data, preferably on a large sample, and comply with the Ministry of Finance scheme – e.g. KSeF uses a dictionary of countries and currencies to which everyone must adapt.
   
6. Map the data to KSeF fields. If business processes use more information than the Ministry’s schema allows, consider how additional data will be shared with contractors.
   
7. Consider what integrations will be made and plan their implementation with support from internal resources or external suppliers. Analyse the situation for today, but don’t forget about the future and the plan in case of changes in KSeF. When choosing an intermediary solution, the obligation to adapt to the changing law should be transferred to the broker’s system – such as SmartKSeF. However, there may always be modifications that will also require updating your systems. Check if there are any projects in progress or planned shortly that will affect the processing of invoices – it would be better to avoid overlapping them simultaneously.
   
8. Analyse the process of issuing and making invoices available to recipients in the context of introducing KSeF, e.g. taking into account the inability to cancel or modify an invoice after sending. Verify internal procedures, employee rights and rules of communication with contractors. Perhaps such changes will force modifications in the systems, e.g. additional roles. If you plan to make invoices available to buyers via KSeF in the optional period until December 31, 2023, remember about the need to obtain the buyer’s approval for receiving e-invoices in this way – the legislator does not impose its form so that you can extend, for example, the existing consent to the transfer of electronic invoices.
   
9. Pay attention to the need to obtain an ID in KSeF to consider an invoice issued in the system. Check the transfer of information from/to contractors. For example, if you require supplier references to your orders on invoices, inform them how they should include them on structured invoices. It may be helpful to take advantage of the experience of companies that, such as Exorigo-Upos, implement similar projects and can help in the analysis and recommend optimal solutions.
   
10. Check the regulations, contracts and other formal documents that may need to be updated due to the implementation of e-invoices. Selected issues to remember are the issue of delivering an invoice, a duplicate, payment deadlines, rules of operation during the period of KSeF failure, etc. This applies to relations with both customers and suppliers.
    
11. Think about whether and how it will be necessary to register UPO in the records. Upon completion of the communication session, KSeF will issue one Official Receipt Confirmation for all invoices issued during the communication session.
    
12. Think about how you want to manage the invoice archive. By law, KSeF guarantees access to e-invoices for 10 years, relieving taxpayers from the obligation to keep records. Consider if you do not want to act “overbooked” for some time and continue your records after launching KSeF.
    
13. Consider the possibilities of optimising existing processes, especially the circulation of purchase invoices. If your law firm scans paper documents, archives them, and recognises the content manually or automatically by OCR before submitting it for further approval, KSeF can streamline this process. Downloading invoices in a uniform format, thanks to intermediary tools such as SmartKSeF, can be supplemented with practical visualisations – this will significantly reduce the number of documents manually entered into various types of systems. Take this opportunity to automate the process up to the step of describing and accepting the invoice. Remember that you will no longer add a comment, initials, stamp or assignment on electronic documents – as with paper printouts. Document flow systems offer many more possibilities than the “analogue” process, but the activities are carried out in the system, not on paper. Remember that not all contractors will be entitled to issue invoices in the KSeF, e.g. in the case of import invoices, so the processes must also handle cases of purchase invoices outside the KSeF. Similarly, in the case of delivering a sales invoice to a buyer who cannot download it from KSeF.
    
14. Pay attention to possible limitations in issuing and access limits of the KSeF API per company. This can be a problem with many distributed domain systems. Analyse whether, due to business requirements, it is not worth using an intermediary solution, such as SmartKSeF, which addresses the problem of potentially slower operation of the Ministry of Finance system and thus ensures the continuity of the invoicing process.
    
15. Consider internal resources for monitoring the operation of communication with KSeF. Potential frequent KSeF API updates should be taken into account. If you do not use an intermediary solution, such as SmartKSeF, your company will be responsible for monitoring the changes and adapting to them.
    
16. Pay attention to individual invoices, including B2C, e.g. an invoice for a consumer without a tax identification number for an e-commerce order, which is also covered by the new obligation to register in KSeF. Let us add, however, that discussions are currently underway with the Ministry of Finance, and these assumptions may change. Also, remember that the correcting VAT invoice in 2024 must reference the e-invoice identifier assigned by KSeF – if the source invoice was issued in the government system. From 2024, a receipt with NIP up to PLN 450 will not be considered an invoice, so if such receipts are currently issued in your company, be prepared for changes in customer service.
    
17. Remember to change the transfer titles. From July 1, 2024, it will be obligatory to provide references to the KSeF or collective identifier, i.e. assigned by KSeF for many e-invoices.
    
18. Consider how you will handle the emergency procedure in case of KSeF unavailability – yourself or using automatic handling in an intermediary solution, such as SmartKSeF. In such a situation, as the Ministry of Finance assures, it will be possible to issue e-invoices by the scheme without sending them to the KSeF. However, it will still be associated with the obligation to register such an invoice with the KSeF – within 7 days. Intermediary solutions will help minimise the impact of KSeF unavailability on invoicing. Still, your company’s systems should handle the situation of, e.g. lack of Internet and transferring the invoice to be issued in KSeF after regaining connectivity.
    
19. Analyse the processes: data preparation for e-invoices, issuing, sharing documents and their transfer. Include all departments in the company that are involved. Although formally, according to the letter of the law, from January 1, 2024, the invoice issued in KSeF will be considered as delivered to the buyer, make sure that customers are not negatively surprised by the change in receiving documents—also, plan training for employees.
    
20. Familiarise yourself with the government’s Taxpayer Application on the Ministry of Finance test environment. Then, identify all persons and companies dealing with invoice handling, including third parties. Give the appropriate permissions. In the case of systemic integration with KSeF, e.g. through intermediary tools, using the Ministry’s portal will usually not be necessary. However, as part of verifying the knowledge of the National Revenue Administration about your company’s invoices, you can authorise yourself with one of the available authentication methods to the company account in the Taxpayer Application to check the status directly in KSeF. Also, consider the procedure for leaving an employee with access to a government portal.
    
21. Start testing e-invoices within the ongoing facultative period as soon as possible. Preparing well in the transition period for the final mandatory invoicing with KSeF is crucial. Also, try unusual cases, e.g. rejection of an invoice by KSeF, the need to correct the invoice or re-sending the invoice to the Ministry’s system.
    • If you start early enough, you can plan communication with the demo environment first so the process goes through the full authorisation path in KSeF. The issued invoice will be a test, and your company will ensure you are ready to meet the e-invoicing obligation.
    • If possible, plan the pilot separately for each system so that any process errors do not simultaneously disrupt all systems that function daily. Until December 31, 2023, the currently used invoices, whether in paper or PDF form, are still a legal form of sales documentation. You can safely return to the current process if you need to correct an error or rollback procedure.
    • Verify activities with critical contractors. Our dedicated team will be happy to carry out such tests in the scope of handling the entire process in SmartKSeF.

We recommend watching a webinar with our expert, created in cooperation with Wiadomości Handlowe.

LINK TO WEBINAR on preparation for KSeF entrance