The Director of National Revenue Information (“Authority”) has recently issued several tax rulings on KSeF obligations that can be relevant for document flow in customer relationships. One of them is ruling of 3 April 2026, ref. nr 0113-KDIPT1-2.4012.1219.2025.2.MC, regarding the issuance of an invoice copy (printout or PDF file) to your customer before the original invoice is uploaded to KSeF and receives its KSeF ID.

The case involved a hotel company which issues online or offline invoices for Polish taxable persons (businesses required to use KSeF), foreign businesses, and consumers. The company wanted to know if, before its invoice reaches KSeF and receives a KSeF ID, it may offer the other party a copy (image) of the invoice (printed or as PDF file) outside KSeF, as it did before at the reception desk during guest checkout. For many businesses, being able to issue a copy of a KSeF invoice even before the invoice receives its KSeF ID may be crucial for keeping the agreed document flow and acceptance schemes with their customers, especially where self-billing is concerned.

The Authority explained rather casuistically that, except for few cases, you generally cannot offer an invoice copy before the invoice is uploaded to KSeF and receives its KSeF ID. In such cases, you are often limited to issuing only what is called a transaction (deal) confirmation. The Authority held as follows:

  • Where an invoice copy is to be issued to a Polish taxable person required to use KSeF, you can offer them an invoice copy only after the invoice is uploaded to KSeF and receives its KSeF ID, whether it was an online or an offline invoice.
  • Where an invoice copy is to be issued to a foreign business (which is not established nor has a fixed establishment in Poland) or to a consumer:
  • if this is an online invoice, you may offer them an invoice copy only after the invoice is uploaded to KSeF and receives its KSeF ID;
  • if this is an offline invoice, you may offer them an invoice copy even before the invoice is submitted to KSeF; you can issue the copy with two QR codes (“OFFLINE”, “CERTYFIKAT”) in such manner as agreed with the customer.

Where the law prohibits issuance of invoice copies before submission of the invoice to KSeF (especially in Polish B2B relations) but the seller must issue some document to the customer for business reasons, they can generate a transaction confirmation (which is not an invoice) for them. It should set out:

  • basic particulars of the parties,
  • issuer’s invoice number,
  • the gross amount,
  • two QR codes.

The ruling makes clear that unrestricted issuance of invoice copies before the originals are uploaded to KSeF will be an exception rather than the rule. Such copies may be safely offered only in relations with foreign customers and with consumers, in an offline mode and in compliance with specific technical requirements. The unavailability of the option to offer invoice copies for acceptance may turn out to be critical for specific business processes, such as self-billing. Be that as it may, the ruling is another of a series of examples of how important it is to implement internal procedures and proper invoicing arrangements that will enable you to discriminate between situations where you may only sent your invoice via KSeF and those where it is correct to generate and offer an invoice copy or a transaction confirmation.

If this issue pertains to your business and you are interested in our assistance, please contact us.

This blog post is provided for general information purposes to keep you up-to-date with changes in tax law, tax rulings by authorities, case law of courts and interesting commentaries. Doradztwo Podatkowe WTS&SAJA shall not be held legally liable for any acts or omissions resulting from reliance on such information.