Poland’s National e-Invoicing System (KSeF) presents risks of unnoticed invoices, fraudulent documents, and lost VAT oversight for businesses, experts warn.
KSeF Risks in Practice: What’s Not Visible in Daily Use
Much discussion around the National e-Invoicing System (KSeF) focuses on false invoices, technical issues, and new company obligations. However, these issues are often overlooked from the perspective of daily business operations and accounting.
These daily workflows reveal the most significant gaps in the KSeF system.
KSeF Doesn’t Manage Invoices, Only Store Them
“From my perspective, the biggest surprise for clients is that KSeF doesn’t ‘manage’ invoices – it only stores them,” says Wojciech Gut, tax advisor and founder of VATAX. “This means responsibility for document control still rests 100% with the entrepreneur.”
Missing Notifications: Invoices Can Exist Before Entrepreneurs See Them
The core issue is invoice receipt and control, not just issuance. According to Gut, the risk begins when a document enters KSeF, as deadlines start from that moment, regardless of whether the entrepreneur is aware of its existence.
An entrepreneur received a payment demand for utilities, surprised to find an invoice in the system when they usually receive them by email. This highlights the need for monitoring tools like Claro, which provide automatic notifications.
Entrepreneurs can easily miss invoices, such as a monthly leasing payment of 3,200 zł, leading to late fees and potential loss of VAT deduction rights.
“Phantom Invoices” in KSeF: False Documents Look Like Real Ones
False invoices in KSeF appear identical to legitimate ones, lacking the filters present in email systems (spam, suspicious senders). A bot could send thousands of small-value invoices that bypass spam filters and appear alongside legitimate invoices.
The primary risk lies in financial loss – a company receiving 30-50 invoices monthly could unknowingly pay a fraudulent invoice for 487 zł. Incorrectly claiming VAT on such an invoice can lead to tax repayment obligations, penalties, and scrutiny from tax authorities.
While reporting abuse is possible, it’s time-consuming, and the invoice remains in the system, potentially being mistakenly booked.
Chaos in Documents: KSeF Stores, Doesn’t Organize
KSeF lacks status indicators, checkboxes, or other organizational tools. Businesses accustomed to email invoices must now actively retrieve them or use automated tools.
At month-end, an accountant requesting documents may find 50 invoices in KSeF without knowing which have been paid, which are from suppliers, or which require clarification, leading to manual reconciliation and wasted time.
This can result in duplicate payments, double bookkeeping, and errors in VAT returns.
KSeF Doesn’t Calculate: Errors Pass Without Verification
KSeF doesn’t perform mathematical calculations. Many assume a KSeF-accepted invoice is correct, which is a misconception. KSeF verifies XML structure but doesn’t check calculations like 100 x 23% equaling 23 zł.
Errors, such as an incorrect VAT rate (32% instead of 23%) or currency exchange rate, can go unnoticed until reconciliation or audit. KSeF also lacks correction notes.
Are Businesses Ready for KSeF?
While approximately 20% of companies had granted system permissions before the KSeF launch, that number has risen to around 90%. The key takeaway is that KSeF alone is insufficient; a control layer is essential to track invoices, identify fraudulent documents, and avoid tax errors.
The problem isn’t issuing the invoice; it’s what happens afterward.
