Many organizations are evaluating the necessity of establishing new guidelines and procedures specific to Polish e-invoicing (KSeF), as well as rules of responsibility and conduct across various domains such as business, accounting, legal, compliance, and IT.

The wide-ranging impact of KSeF, including the introduction of entirely new roles (e.g., KSeF administrator) and updated contractual requirements (such as invoice transmission methods, payment terms, and protocols for invoicing during system outages), encourages the creation of a comprehensive KSeF procedure by Polish entities. This document articulates operational expectations in the evolving landscape, outline strategic directives for agile business responses, and clarify how support functions can effectively safeguard these activities. Additionally, developing such procedures provides an opportunity to reassess whether core areas critical to business continuity and security are sufficiently protected.

On this occasion, it is important to consider all relevant procedures and internal documentation – including fundamental documents such as the accounting policy and document workflow / electronic document management, as well as tax policy.

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Is an update of the accounting policy necessary?

An accounting policy comprises a framework of rules and organizational solutions designed to ensure that bookkeeping is conducted in accordance with the Accounting Act. Its primary function is to guarantee regulatory compliance while safeguarding the interests of the enterprise, taking into account its unique characteristics, needs, and available resources.

Pursuant to Article 10 of the Polish Accounting Act, each entity is required to specify in its accounting policy, inter alia:

  • the method of maintaining accounting records,
  • the structure of the accounting records, including interrelationships and functions,
  • the system for processing data and documents, and
  • the data protection system, including accounting evidence (the form of which is affected by KSeF), as well as methods for securing access to data and to the systems used for processing such data.

Key considerations such as the introduction of structured invoices, contingency modes, revised archiving rules, data integration methodologies between KSeF and the accounting system, additional IT solutions supporting KSeF, access rights/authorizations, and the absence of correcting notes for minor errors on purchase invoices are among the areas directly impacted by KSeF. Existing practices concerning invoice circulation, documentation, and data protection must therefore be reviewed and, consequently, updated at a minimum within the accounting policy.

The accounting policy should accurately reflect the actual operation of financial and accounting processes; otherwise, there is a risk of divergence between practice and documented procedures. During an audit of the financial statements, an auditor may identify a lack of updates as an issue, potentially viewing it as a weakness in the internal control framework. Some auditors are already recommending implementing such changes.

Document workflow, tax policy, and other internal documentation

The document workflow should clearly define the stages for processing, inter alia, invoices – from issuance or receipt within KSeF, through verification and approval, and ultimately through posting and archiving. It is essential to address contingency modes (e.g., lack of access to KSeF) and to establish clear rules for granting permission to use the system.

Tax policy often also sets out the methodology for handling invoices, including required approvals and actions confirming the correctness of their recognition, mandatory attachments, and methods for correcting data (including via notes). These processes are evolving, and the Ministry of Finance’s expectations regarding due diligence are increasing. In addition, preparation of JPK_VAT will also require connectivity with KSeF to supplement KSeF numbers and apply new markers.

A thorough review of the above procedures as well as other internal documents in force within the organization, both from the perspective of current legal requirements and of processes affected by KSeF, should form an integral part of the periodic review of internal documentation.

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At CRIDO, we design and implement procedures to verify (preferably before the launch of KSeF) whether an organization has addressed the key aspects of working with KSeF, and whether future day-to-day operations across sales, procurement, logistics, finance, accounting, legal, and IT functions will be compliant with applicable regulations. This includes ensuring effective allocation of responsibilities across procurement and sales processes, customer relationship management, and tax reporting.

We identify the areas that require consideration in connection with the introduction of KSeF within the organization, provide recommendations, and tailor documentation to the company’s structure, industry, and the needs of system users.

We encourage you to get in touch if you need support in this aspect of working “with KSeF”!