Purchase Note and Expenses Without an Invoice in a Sole Proprietorship in Poland in 2026

Bought small equipment, paid cash, and didn't get an invoice? Or received a bill that isn't a VAT invoice? Since 2026, the rules for recording such expenses in a sole proprietorship (JDG) are precise: without the right document, there is no cost in the tax revenue and expense book (KPiR). But the right document isn't always an invoice.

We explain what constitutes an accounting document in the KPiR (Art. 22 ust. 1 and 6b of the PIT Act), how to prepare a purchase note, and when you can — and cannot — record an expense without an invoice.

What the PIT Act says

Art. 22 ust. 1 of the PIT Act (Dz.U. 2026 poz. 592 t.j.) defines deductible expenses (KUP) as costs incurred to earn revenue or to preserve or secure the source of revenue, except those listed in Art. 23 (costs that cannot constitute KUP).

Art. 22 ust. 6b states that for taxpayers maintaining the KPiR, the date of incurring the cost is the date of issue of the invoice, bill, or other document that serves as the basis for recording the cost, subject to statutory exceptions.

The key phrase: "other document." It does not have to be a VAT invoice — but it must be a document meeting specific requirements.

Hierarchy of expense documents

1. VAT invoice (strongest evidence)

A standard VAT invoice with date, number, seller and buyer details, description of goods/services, and net/VAT/gross amounts. It provides a basis for VAT deduction (for an active taxpayer) and for recording the cost in the KPiR.

2. Simplified invoice / receipt with NIP up to 450 zł

A fiscal receipt with the buyer's tax identification number (NIP) up to 450 zł gross (or 100 euro) is treated as a simplified invoice (Art. 106e ust. 5 pkt 3 of the VAT Act). It entitles you to deduct VAT and record the cost in the KPiR.

Above 450 zł — a full VAT invoice is required.

3. Bill (not an invoice)

A bill is issued by an entity that is not a VAT taxpayer (e.g., a private individual not conducting business activity). A bill does not contain VAT and does not entitle you to deduct VAT. However, it is an accounting document in the KPiR — provided it meets the requirements.

4. Purchase note (internal document)

When you do not have an invoice or a bill, you can prepare a purchase note — an internal document drawn up by the taxpayer. This is the evidentiary last resort, accepted by tax authorities when specific conditions are met.

How to prepare a purchase note

A purchase note must contain:

1. Date of the expense — the day of the actual purchase,
2. Amount of the expense — the purchase price,
3. Subject of the purchase — what exactly was bought (name of goods/service),
4. Purpose of the business connection — why the purchase serves the business (link to revenue),
5. Method of payment — cash, bank transfer, card,
6. Taxpayer's signature — a declaration that the cost was incurred.

Example note

NOTATKA ZAKUPOWA Nr NZ-001/2026

Data wydatku: 15.07.2026
Wystawiający: Jan Kowalski, NIP 1234567890
Przedmiot: Papier do drukarki A4, 5 ryzyk
Kwota: 120 zł (słownie: sto dwadzieścia złotych)
Cel: Materiały biurowe do działalności księgowej
Sposób zapłaty: gotówka
Sklep: sklep papierniczy przy ul. Długiej 5, Warszawa

Podpis przedsiębiorcy: [podpis]

Limitations of the purchase note

• No VAT deduction — the purchase note is not a VAT document and does not entitle you to deduct VAT,
• Lower evidentiary value — tax authorities treat the note as supplementary evidence; during an audit they may request additional confirmation,
• Reasonable amount — purchase notes are credible for small expenses (up to a few hundred złoty). For larger amounts, tax authorities expect an invoice or a bill.

What can be booked without an invoice

Expenses where an invoice is not required

Some costs can be documented without a VAT invoice:

• Per diems and travel allowances for business trips — based on a trip settlement (not a hotel invoice),
• Depreciation — calculated from the initial value of a fixed asset, not documented with a monthly invoice,
• Material consumption — materials entered into inventory via an invoice, consumed without further documentation,
• Financial costs — bank fees confirmed by a bank statement,
• Loan interest — confirmed by a repayment schedule and bank statement.

Expenses where an invoice (or equivalent document) is required

• Purchase of goods for resale — invoice or customs document,
• Outsourced services — invoice or bill,
• Fuel, servicing, car repairs — invoice or receipt with NIP up to 450 zł,
• Equipment and furnishings — invoice,
• Premises rental — invoice or lease agreement.

Pitfalls

1. Plain receipt without NIP — is not an accounting document. You must request a receipt with NIP or an invoice.
2. Note instead of invoice for large expenses — tax authorities question purchase notes for amounts above a few hundred złoty. Where an invoice is possible, one should be obtained.
3. Missing purpose description — a purchase note without an explanation of the business connection is invalid as an accounting document.
4. Document date vs. payment date — since 2026 (Art. 22 ust. 6b), the date of incurring the cost is the document's issue date, not the payment date. Keep this in mind for year-end expenses.
5. Deducting VAT from a note — a purchase note is not a VAT document. VAT cannot be deducted, even if VAT was included in the price.
6. Simplified invoice above 450 zł — a receipt with NIP above 450 zł is not a simplified invoice. You need a full invoice.

FAQ

Can a plain receipt without NIP be booked in the KPiR?

No. A plain receipt without NIP is not an accounting document. You must request a receipt with NIP (up to 450 zł) or a VAT invoice.

Can a purchase note be made for any amount?

Theoretically yes, but in practice notes are accepted for small expenses (up to a few hundred złoty). For larger amounts, tax authorities expect an invoice or a bill.

Can VAT be deducted from a purchase note?

No. A purchase note is not a VAT document and does not entitle you to deduct VAT.

Is a bill (not an invoice) sufficient for the KPiR?

Yes. A bill issued by a private individual who is not a VAT taxpayer is an accounting document in the KPiR. However, it does not entitle you to deduct VAT (because there is no VAT).

Does an employee cash advance require an invoice?

Settling a cash advance (e.g., per diem, travel allowance) does not require an invoice from the employee — a trip settlement prepared by the entrepreneur suffices.

Sources

• PIT Act — Art. 22 ust. 1 and ust. 6b (Dz.U. 2026 poz. 592 t.j.)
• VAT Act — Art. 106e ust. 5 pkt 3 (Dz.U. 2025 poz. 775 t.j.)
• Regulation on the KPiR (Dz.U. 2019 poz. 2544)

Need help with your expense documentation?

Oxyok maintains the KPiR and helps organize sole proprietorship expense documentation — from 49 zł + VAT per month.

Write to Paweł or see Oxyok's accounting services.

This material is for informational purposes. Expense documentation should be tailored to your individual situation.