National e-Invoicing and how to account for expenses incurred by employees while on a business trip

This article answers the following questions:

• How to account for employee business trip expenses in the National e-Invoice System?
• How to get your business ready for the new rules for settling business trips?

The National e-Invoice System (known in Polish as KSeF) is a Polish IT system which will become mandatory in Poland in 2026, affecting a multitude of areas of running a business – including the settlement of business trips and accounting for other expenses incurred by employees.

Until now, employees of Polish taxable persons traveling on business and incurring related expenses often documented their trip with paper invoices, collected during their travel and forwarded to their employer's accounting team upon return. Fortunately, the rollout of e-invoicing will simplify this process – provided, of course, that companies implement appropriate procedures.

How will the settlement of employee business trip expenses change?

With the launch of the KSeF, all companies – including hotels, restaurants, and other entities whose services employees typically use during business trips – will be required to issue structured invoices. This means that business trip expenses will also be documented using e-invoices, so employees traveling on business will not receive a physical document to forward to the accounting team.

In the new system, an invoice for a hotel or restaurant meal will automatically be transferred to the extensive record of purchase invoices received by a given company in KSeF, and the accountant will have to manually locate it. Furthermore, since the accounting team will collect invoices required for business trip expense settlement directly from KSeF, the use of previously developed methods for employee invoice marking (e.g. by adding notes identifying the employee who incurred the expense or tagging the invoice with a business trip number) will no longer be possible.

Please note that the structure of FA(3) schema, applicable under the National e-Invoice System, contains a field allowing for the indication that the recipient of a given invoice is an employee, however, the regulations do not impose an obligation on sellers to fill it in.

In practice, this may mean that a significant number of sellers will either be reluctant to complete the employee identification field, will not be aware of such an option, or – unless the employee explicitly requests it – will routinely skip this field. On the other hand, issuing invoices in KSeF may result in the process of settling business trip expenses being completely digitised and, as a result, it will be greatly facilitated and better organised within individual companies.

How to prepare for the new rules governing the accounting for invoices related to business trips?

Companies that send employees on business trips as part of their operations should, first of all, conduct an audit of the accounting software in place as soon as possible and verify whether it is possible to implement an automatic system for classifying invoices related to business trips in the currently used ERP software.

It will also be necessary to modify the procedures governing the settlement of business trips and other expenses incurred by employees on behalf of the employer, as well as to provide training and raise awareness among the staff.

Additionally, the regulations allow employees on a business trip to ask a hotel or restaurant (or any other entity related to expenses incurred during a business trip) for a visualisation of the invoice or transaction confirmation. The Ministry of Finance indicates that such a transaction confirmation will protect the buyer's interests in situations where the invoice issued online or offline does not yet have a KSeF number. The transaction confirmation and the QR codes included on it will allow access to the structured invoice and verification of the data. However, such a confirmation will not constitute a structured invoice.

Structuring processes is the key to efficient settlement of business trip costs

The new rules governing the issuance of structured invoices may pose a challenge in terms of accounting for employee business trip expenses, especially if a company sends multiple employees on a business trip simultaneously. However, getting ready for the changes (and determining how the company will link invoices received in the KSeF with incurred employee expenses) and properly setting up company processes can contribute to the automation and digitisation of company settlements with employees travelling on business and bring tangible organisational benefits by streamlining internal processes.

If you are considering implementing procedures to systematise the settlement of business trips in KSeF – or have any doubts regarding structured invoices – we encourage you to contact our tax and accounting advisors and check out our KSeF support offer.