Self-billing in KSeF: the buyer and people authorised by the buyer

Self-billing in KSeF: who can issue invoices?

The seller may grant the buyer self-billing permission in KSeF. Once this permission has been granted, the buyer may issue invoices on the seller’s behalf directly in KSeF. This is how Poland’s Ministry of Finance describes the mechanism in answer 10 of its frequently asked questions.

Does the buyer have to issue invoices personally?

The buyer is not the only one who can use this mechanism. Once the buyer has received permission from the seller, people whom the buyer authorises may also issue invoices on the seller’s behalf directly in KSeF. This is an option identified in the same Ministry answer, not an obligation to involve additional people.

Three roles can therefore be distinguished:

• Seller — may grant the buyer self-billing permission in KSeF.
• Buyer — after receiving this permission, may issue invoices on the seller’s behalf directly in KSeF.
• People authorised by the buyer — under this mechanism, they may also issue invoices on the seller’s behalf directly in KSeF.

Technical permission and legal assessment

This description concerns only the permission mechanism in KSeF. Do not treat the granting of technical permission alone as proof that all legal conditions for self-billing have been met. This article does not assess whether self-billing is permissible for a particular transaction.

An optional organisational checklist

To clarify the roles, you can prepare your own note identifying:

• the seller on whose behalf invoices are to be issued;
• the buyer to whom the seller intends to grant self-billing permission;
• the people whom the buyer intends to authorise, if the buyer wishes to use this option.

This is an organisational suggestion, not an official form or an additional obligation. Do not treat it as confirmation that the legal conditions for self-billing have been met.

Do not confuse this with an accounting firm’s access

The Ministry separately discusses an accounting firm’s permissions to issue and view invoices in answer 17. Do not equate that topic with the self-billing permission granted to the buyer described here.

The special designation of the buyer for VAT RR and cross-border self-billing are outside the scope of this article. The description presented here should not be applied to those matters without separate analysis.