Self-billing with a foreign contractor
On December 9,
2025, new Regulations of the Minister of Finance and Economy concerning
situations in which there is no obligation to issue structured invoices, i.e.,
invoices to KSeF, were published in the Journal of Laws of the Republic of
Poland, item 1740.
Simply put, §
2. points 5 and 6 of the regulation state that
5) If your
(foreign) customer, who is not identified by a tax identification number (NIP),
issues your sales invoice as part of self-billing, you do not have to send this
sales invoice to KSeF
6) If you issue a
sales invoice to your (foreign) customer on their behalf as part of
self-billing, and they are not identified by a tax identification number (NIP),
you do not have to send this sales invoice to KSeF
Therefore, next
year it will also be possible to use self-billing with foreign contractors. It
will not be necessary to issue a sales invoice or its equivalent solely for the
purposes of KSeF.
The remaining points of the regulation confirm:
1) Motorway tickets
will be accounted for in 2026 as before
2) Public transport tickets will be accounted for in 2026 as before
3) For airlines that pay so-called route charges, EUROCONTROL will continue to issue invoices centrally on behalf of the Polish Air Navigation Services Agency.
4)
Services exempt from VAT
pursuant to Article 43, points 7 and 37-41 do not have to be sent to KSeF:
- Currency exchange
- Insurance
- Credit and loan services
- Sureties, guarantees, and other financial collateral
- Banking services in general, for which a fee or commission is charged
- Services involving financial instruments.
The full and accurate text of the regulation can be downloaded from:
