Is the visualisation of a KSeF invoice not as alarming as it seemed? The tax authorities change their position

The requirement to issue invoices through the National e-Invoicing System (Polish: Krajowy System e-Faktur – KSeF) has been in force for some time now, and Polish taxpayers have gradually become accustomed to the new rules. Unfortunately, although the most significant changes have been implemented without major difficulties and the system operates relatively effectively, doubts still arise from time to time, and the interpretations issued by the tax authorities do not always provide answers that are sufficiently clear for businesses. One particularly interesting issue concerns the risk of issuing empty invoices where a structured invoice (in XML format) submitted to KSeF differs from the subsequent visualisation of the document (e.g. in PDF format), which contains additional information intended for the recipient.

Initially, the tax authorities maintained that an invoice visualisation differing by any detail – even the smallest one – from the document stored in KSeF could indicate duplicate invoicing of the same business transaction. The latest interpretation sheds a different light on the matter. What is the current position? From the perspective of tax advisers and accountants, the situation is far from ideal, but it is not disastrous either.

Early tax rulings concerning e-invoice visualisations offered little reassurance...

In April 2026, tax rulings began to appear addressing whether, after submitting an invoice to KSeF and preparing its visualisation, a taxpayer may add an additional annotation to the latter document which does not fall within the scope of invoice elements specified in Article 106e of the VAT Act. 

In other words, the question arose whether adding something to the visualisation of an e-invoice results in the creation of a new, separate invoice. The interpretation of 30 April 2026 (reference no. 0114-KDIP1-1.4012.84.2026.2.EW) suggested that it does.

This was not good news for taxpayers. In many industries, additional annotations on invoices are an everyday practice, and in the case of structured invoices the only place where such notes can be added (following issuance through KSeF) is their visualisation. The tax authorities nevertheless considered that such action may create a risk of duplicate invoicing of the same transaction.

It therefore appeared that taxpayers had found themselves in a blind alley. As is often the case, however, three months later the tax administration changed its position and presented a different interpretation.

...but a new interpretation of the Head of the National Revenue Administration Information Centre allows certain elements to be added to KSeF invoice visualisations

The stringent April interpretation gave rise to numerous concerns among both tax advisers and businesses. For many companies, the implementation of KSeF already required a strict adaptation of the invoicing process to the structured XML format and the removal of some information previously included on invoices. The interpretation discussed above further confirmed the tax authorities’ highly restrictive approach, even with regard to visualisations.

A more optimistic outlook emerged with the interpretation of 15 July 2026, reference no. 0112-KDIL1-3.4012.317.2026.1.ŁW. In that interpretation, the Head of the National Revenue Administration Information Centre (NRAIC) concluded that additional technical, logistical or commercial information may be included in an invoice visualisation.

What do the Polish tax authorities consider to be permissible technical, logistical or commercial information? This may include, among other things:

• information regarding a commercial discount, 
• the customer’s logo, 
• the customer code from an internal system, 
• the country of origin of the goods, 
• technical specifications of the goods (e.g. weight or number of pallets), 
• delivery details. 

Taxpayers are still not permitted to supplement a KSeF invoice visualisation with information concerning the subject matter of the transaction if such information was not included in the structured invoice. 

This means that the tax authorities have moved from a highly restrictive and taxpayer-unfriendly approach to a more pragmatic position.

The tax authorities have changed their position, but concerns remain. How can additional information be safely added to a KSeF invoice visualisation?

Less than three months were enough for the NRAIC to change its approach to the issue of adding supplementary information to KSeF invoice visualisations. We have moved from a complete prohibition on adding any content whatsoever to a visualisation to a situation in which a taxpayer may indicate, for example, the number of pallets on which goods were delivered.

Will we see a further liberalisation of the tax authorities’ position in another three months? At present, this remains uncertain. Taxpayers should nevertheless exercise caution and carefully analyse what information they include, and where they include it, on KSeF invoice visualisations. In cases of doubt, it remains advisable to consult a tax adviser rather than rely on the tax administration’s leniency, as mistakes in this area may have serious consequences and may result in a tax audit and penalties.