The inability to add custom notes to cost documents in the National e-Invoice System may create complications for businesses. The stripped-down format leaves many invoices without context, raising the risk of errors in tax settlements and issues during audits.
The KSeF system does not include any fields for buyers to attach personal or system-generated annotations. Previously, entrepreneurs would often make handwritten or digital notes on invoices to remind themselves later of the purpose of a purchase – for example, whether it was a piece of equipment, a service, or a training expense. Now, with e-invoices being essentially bare, the rationale behind a transaction is frequently lost.
One invoice, two different tax treatments
A case reported by a dental clinic illustrates the problem. The invoice listed an item with a Latin name that suggested a specialised piece of equipment. In reality, the expense was for a training course – and the two are treated differently for tax purposes. Without the ability to annotate the invoice itself, such confusion can become much more common under the new system.
Business owners are consequently being forced to go back to paper-based methods. Many are printing out e-invoices and writing notes on them manually. Others create internal supporting documents that describe the nature, purpose and business connection of each expense.
Extra work for entrepreneurs
– This documentation will certainly be useful if the tax office ever checks whether the costs are linked to business activity. But it is clearly extra work for entrepreneurs – said Aleksandra Kozak, owner of the accounting firm Konto.
The extra burden falls mainly on small and medium-sized enterprises that lack dedicated accounting software with built-in note fields. For them, every printed and annotated invoice means more time spent on administration, and a greater chance of human error.
What can be done?
Experts advise keeping consistent internal records alongside the KSeF invoices. A simple spreadsheet or a set of internal vouchers with clear descriptions can serve as a reliable backup. Tax authorities have so far not issued any formal guidance on whether such supplementary notes are admissible, but accountants recommend having them ready in case of an audit.
The Polish government maintains that KSeF is designed to streamline invoicing and combat VAT fraud. Yet as the system matures, regulators may need to consider adding a dedicated annotation field or allowing attachments to e-invoices. Without that, many entrepreneurs are left to improvise – and the risk of costly misunderstandings lingers.
Źródło: WNP.PL, Fot. Dorota Szymczyk/Shutterstock
