Polish businesses using the National e-Invoicing System (KSeF) can legally provide English translations of Polish invoices for international clients and banks.
Problem
Polish companies utilizing the National e-Invoicing System (KSeF) frequently face the challenge of providing documentation understandable to foreign clients or financial institutions, as the system doesn’t support full foreign-language invoices.
A company director needed to issue an invoice to a foreign client whose bank required an English version for payment processing, and worried about accusations of falsifying documents by creating a separate translation.
Advice
It is permissible to issue an invoice in Polish, compliant with KSeF requirements, and then attach an English translation as a separate document, clearly labeled as a “translation of the invoice.”
The translation can be prepared by anyone proficient in English and does not require notarization or a sworn translator, unless specifically required.
System Limitations: Polish-Only KSeF Invoices
The National e-Invoicing System is designed to comply with Polish tax regulations, which dictate the language of the documents. Consequently, structured invoices must be issued in Polish, even for international transactions.
While some foreign language elements, such as service or product names in English, are permissible, the document remains formally a Polish-language document.
Translation as a Safe Solution
Tax experts recommend preparing a translation of the invoice as a separate document as the simplest and legally compliant solution.
Tax advisor Grzegorz Ziółkowski emphasizes the importance of clearly distinguishing the original from its translation.
“The invoice must be issued in accordance with Polish regulations. If the recipient needs an English version, a translation reflecting the content of the original document should be prepared,” he explains.
Risk of Duplicate Invoices and Tax Consequences
Issuing a second document resembling an invoice, even in a different language, could be treated by tax authorities as a “void invoice” or a duplicate sales document, potentially leading to sanctions and criminal-fiscal liability.
Therefore, experts strongly advise against any “workarounds” involving issuing additional English-language invoices, as they carry a high risk.
Who Can Translate the Invoice?
Contrary to concerns, Polish regulations do not require invoice translations to be performed by a sworn translator.
Unless a specific requirement exists—such as from a particular institution—the translation can be prepared by anyone proficient in the foreign language.
This means a company can translate the invoice themselves or assign it to an employee, ensuring the document clearly indicates it is a translation, identifies the translator, and includes the translation date.
How to Prepare an Invoice Translation Step-by-Step
The invoice translation should faithfully reflect the layout and content of the original.
The most common method is to create a document that visually resembles the invoice but clearly states it is a translation.
The document should include: a clear indication that it is a “translation of the invoice.” There is no obligation to create a bilingual version—a complete translation into English is sufficient.
Bank Requirements and International Practice
Many businesses report that banks frequently require documents in English, which experts note stems from internal procedures rather than legal requirements.
Formally, a bank should accept a Polish invoice and request a translation if needed, but in practice, the burden of providing the translation falls on the business.
It’s advisable to contact the bank before preparing documents to confirm acceptance of a non-sworn translation, avoiding unnecessary costs and delays.
Invoice Language in International Trade: Regulations and Practice
The rules regarding invoice language in Poland are based on tax regulations and accounting documentation requirements.
They do not prohibit the use of foreign languages but require documents to be understandable to tax authorities, who may request a Polish translation if the original is in a foreign language.
