Major companies are publishing guidelines on sales documentation under Poland’s new mandatory e-invoice system, potentially imposing their own processes on business partners.
Major Companies Publish KSeF Documentation Guidelines
Major companies are publishing communications about how to document sales and purchases after the introduction of the mandatory Krajowy System e-Faktur (KSeF). Sometimes these communications even specify in what form purchase documents will be accepted by these entities.
Dual Interpretation of Corporate Communications
Such actions can be interpreted in two ways. On one hand, they can be seen as part of an information campaign, support for the Ministry of Finance in promoting information about KSeF, and preventive actions to avoid conflict situations.
Market Dominance Concerns
However, it appears that a more significant purpose may be for companies with dominant market positions to impose their own processes on their counterparties, both customers and service providers. Worse still, these mechanisms are not always fully correct or friendly to counterparties.
Unclear Guidance
Often the guidelines are imprecise and don’t actually provide answers to basic questions about transaction documentation. For example, how should one understand the explanation in the Orlen communication: “In cases justified by business, the visualization of the KSeF invoice with the appropriate QR code marking may be made available to the counterparty in a manner agreed with them”?
Open to Interpretation
In essence, this is an open provision that allows for arbitrary, discretionary application. It gives companies the freedom to interpret and apply the rules as they see fit, potentially creating uncertainty for their business partners.
