KSeF and foreign invoices in Poland: WDT, WNT, exports, and imported services

How KSeF applies to foreign sales, WDT and exports, as well as WNT and imported services. Delivering a PDF with a QR code, FE, and self-billing.

A cross-border transaction is not automatically excluded from KSeF. You must separately assess the Polish seller’s obligations, the method of delivering an invoice to a foreign buyer, and the purchase documents received from suppliers outside Poland.

The common shortcut “foreign transactions are outside KSeF” causes errors in both directions. A Polish business owner may have to issue a KSeF invoice to a customer in Germany or the United States even though that customer will not retrieve it directly from the Polish system. At the same time, an invoice from a foreign supplier will usually not appear in KSeF and must still be delivered to the accounting team through another channel.

Foreign sales by a Polish business owner

If a Polish seller is subject to the KSeF mandate, as a rule they issue B2B sales invoices for foreign customers through the system. This includes, among other things:

an intra-Community supply of goods, known in Poland as WDT,
exports of goods outside the European Union,
services provided to a foreign business where the transaction requires an invoice.

The place of taxation, VAT rate, and required annotations depend on the transaction type. KSeF does not turn WDT into a domestic sale or determine whether the conditions for the 0% rate have been met. The system is a method of issuing an invoice, not an automatic determination of its VAT treatment.

Before submission, correctly identify the buyer, their country, and their EU VAT number or other identifier. It is also worth checking whether your software can handle foreign currencies, the relevant markings, and the data required for the specific type of supply or service.

The general rules of the mandate and the FA(3) structure are explained in the guide KSeF for a JDG in Poland in 2026.

How to deliver an invoice to a foreign buyer

A foreign business will not usually retrieve the document from KSeF in the way a Polish buyer with a NIP does. After issuing the invoice in the system, the Polish seller therefore delivers its visual representation by an agreed method, such as a PDF sent by email or through a customer portal.

A visual representation delivered outside KSeF should contain the correct QR code with the KSeF number. The code makes it possible to verify the document’s data and access the invoice in accordance with the system rules. The PDF itself does not replace the source structured invoice, but it provides the business partner with a readable delivery format.

The agreement or order should specify:

the email address or delivery portal,
the accepted language of the visual representation,
the attachment format,
the method of delivering corrections,
a contact person in case the QR code cannot be read.

KSeF does not release the seller from the practical obligation to deliver the document to a recipient who does not use the Polish system. Your own proof that the PDF was sent and the UPO from KSeF document two different stages, and both should be retained.

An invoice issued offline for a foreign business partner

If an invoice is delivered to a foreign recipient before being submitted to KSeF under an offline procedure, the visual representation requires two QR codes: OFFLINE and CERTYFIKAT. The second code is generated using a type 2 KSeF certificate and confirms the issuer’s identity.

Once KSeF accepts the document and assigns a number, a visual representation with a single QR code linked to the KSeF number is sufficient for further circulation outside the system. Submission deadlines depend on the procedure used. See KSeF offline24, unavailability, and outages for details.

Purchases from foreign suppliers

Purchase invoices issued by a foreign supplier generally do not appear in KSeF. This applies to typical documents related to:

WNT, meaning the acquisition of goods from another EU member state,
imported services,
imports of goods,
purchases of digital services, licences, advertising, or subscriptions from a foreign entity.

If a business buys advertising, software, or consulting services abroad, the document may still arrive by email or be downloaded from the supplier’s portal. The absence of an invoice from KSeF does not mean that the document is invalid or that the transaction does not need to be accounted for.

The business owner should maintain a separate document flow for foreign invoices. The software provider or accounting firm must receive the PDF, payment details, and information needed for the tax treatment. For WNT and imported services, the Polish buyer may be required to report VAT even though the invoice never entered KSeF.

KSeF does not account for WNT or imported services on the taxpayer’s behalf

KSeF stores structured invoices covered by the system, but it does not replace VAT records or JPK_V7. The information needed to account for WNT, imported services, or imported goods may come from documents outside KSeF, customs documents, contracts, and confirmation that a service was performed.

The accounting team should determine, among other things:

the transaction type and place of taxation,
when the tax liability arises,
the correct exchange rate,
the taxable amount,
output VAT and any right to deduct it,
required record-keeping codes.

Do not build a process in which the accountant retrieves documents only from KSeF. Such a model will omit a significant share of foreign purchases, as well as other valid documents issued outside the system.

Take care when a fixed establishment is involved

The position of a foreign entity may change if it has a fixed establishment in Poland, abbreviated as FE. The crucial question is not only whether such an establishment exists, but also whether it participates in the particular supply of goods or services.

A foreign entity with neither a registered office nor a fixed establishment in Poland is not subject to the requirement to issue invoices in KSeF. If it has a Polish fixed establishment but that establishment does not participate in the transaction concerned, the entity may also qualify for the exclusion. Polish VAT registration alone therefore does not automatically determine whether the KSeF mandate applies.

Assessing FE requires analysis of the specific facts: human and technical resources, the permanence of the presence in Poland, and the involvement of that structure in the transaction. Do not make the decision solely on the basis of a VAT number. The Ministry of Finance has published separate guidance on fixed establishments for KSeF purposes.

Self-billing with a foreign buyer

Under self-billing, the buyer issues the invoice on the seller’s behalf. KSeF permits this model, but the seller must first grant the buyer the appropriate permission.

For WDT, a buyer in another EU member state using an EU VAT number assigned for intra-Community transactions may voluntarily issue an invoice through KSeF on behalf of the Polish seller after receiving the appropriate permission. At the same time, official answers indicate that invoices issued by foreign entities under self-billing arrangements with a Polish seller are not generally subject to mandatory KSeF.

It is particularly easy to draw an overly broad conclusion in this area. Before implementation, check the buyer’s country and status, EU VAT number, the self-billing agreement, the scope of permission, and both parties’ technical capabilities. Merely sending data to a customer portal does not by itself mean that the document has been correctly issued through KSeF.

The article KSeF permissions for an accountant and accounting firm explains how to grant access securely.

A procedure for a business trading internationally

On the sales side, separate issuing the invoice through KSeF from delivering it to the business partner. The software sends the XML, checks acceptance, and records the UPO, then creates a readable visual representation with the correct QR code and delivers it through the agreed channel.

On the purchasing side, retain a mailbox or portal for receiving foreign documents. The accounting team should periodically reconcile invoices against card payments, bank transfers, and subscriptions to identify missing documents.

Entities that may have an FE in Poland and self-billing agreements require separate analysis. KSeF standardizes domestic invoice circulation, but it does not remove the differences between WDT, WNT, exports, imports of goods, and imported services.