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Check the issuer and the 2026 transition
The Ministry’s scope page starts mandatory issuance on 1 February 2026 for taxpayers whose 2024 sales including VAT exceeded PLN 200 million, and on 1 April 2026 for the others subject to exclusions. Through 31 December 2026, the temporary outside-KSeF route covers the stated paper/electronic invoices where the relevant monthly gross sales do not exceed PLN 10,000; check the applicable counting rules.
An issuer with neither its business seat nor a fixed establishment in Poland is excluded. A foreign issuer with a Polish fixed establishment is also excluded where that establishment does not participate in the supply. Consumer invoices and specified transaction/procedure categories have other exclusions. An American customer is therefore not, by itself, an exemption for a covered Polish supplier.
Send the customer a readable version of the issued invoice
For the covered ordinary online process, the Ministry FAQ addresses foreign customers outside the EU and without a Polish NIP tax identifier. Issue through KSeF, Poland’s National e-Invoice System, then provide the customer’s copy through an agreed channel. The buyer need not acquire a Polish login merely to pay you.
The customer version may be in English, but its substance must match the XML, the structured record sent to KSeF. Include the applicable QR code and KSeF reference. Agree how the buyer receives it and retain that delivery record; do not create a second, inconsistent invoice.
Keep delivery evidence separate from the invoice
If an American customer later disputes monthly support, the issued invoice and matching copy identify the bill. They do not establish which support was accepted. Keep acceptance protocols or shipment records separately; the FAQ says they are not simply attachments carried inside KSeF.
Reconcile payment, currency differences and corrections to the appropriate invoice records. Offline and outage modes have different QR and resubmission conditions, so do not copy this online sequence into those situations.
Scope
- The described process is ordinary online issuance, not offline/outage contingencies. The 2026 transition route and exclusions require actual issuer, establishment, transaction and invoice-total facts; no universal VAT, withholding or U.S. tax outcome is supplied.
Next step
Confirm the covered invoice mode, agree the customer-copy channel and make sure the readable copy matches the system invoice.
Sources & review notes
Polish Ministry of Finance
Passage, dates and research notes
official-guidance · Issuing for non-EU/foreign recipients; visualisation/QR; documents outside KSeF; scope and 2026 transition
Dlatego sprzedawca musi przekazać mu dokument w uzgodniony sposób
Polish original. Read the named scope, recipient, visualisation/QR, delivery and additional-document answers in full, not every unrelated FAQ. AI-assisted English summary. Foreign recipient answer assumes a recipient without Polish NIP; it is not a statement about all foreign fixed establishments. The ministry describes 2026 staged introduction and transitional exceptions; actual issuer/transaction obligation still needs checking. Distinct online versus offline QR and timing rules exist; this guide covers the ordinary online case, not offline contingencies.
Polish Ministry of Finance
Passage, dates and research notes
official-guidance · Complete rollout and exclusion explanation
1 kwietnia 2026 r. dla pozostałych podatników
Full official scope page read in Polish with AI-assisted interpretation. Temporary PLN10k route and 31 December 2026 end retained; no foreign-customer blanket exclusion. Special procedures and simplified-document/self-billing exclusions remain applicable; ordinary online article is not a full invoice-mode manual.
Detailed rule records (1)
For a covered online invoice, the ministry FAQ describes issuance in KSeF, a consistent foreign-recipient visualisation through an agreed channel and the applicable QR/KSeF reference. Additional acceptance/shipping documents remain outside KSeF. Confirm issuer scope and transitional exceptions separately.
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