National e-Invoicing System in Poland (KSeF) and scam invoices: why document control is essential

National e-Invoicing System in Poland (KSeF) is changing how invoices are issued, received and circulated within a company, but it does not remove the need to verify them on the buyer’s side. The mere fact that a document has been retrieved from the system does not mean it should automatically be posted to the books. In practice, invoices issued by mistake, documents requiring additional clarification and so-called scam invoices are becoming increasingly important. These are the types of documents that should be stopped and assessed before any further processing takes place. KSeF is used to issue, transmit, receive and store structured invoices, but it does not make the business decision for the entrepreneur as to whether a particular document should be accepted for settlement. That decision still remains with the company.

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Why this topic matters in Poland right now

Since 1 February 2026, the production version of KSeF 2.0 has been in operation, and the obligation to receive invoices through the system has applied from that date. Since 1 April 2026, the second phase of the rollout has covered entrepreneurs whose sales value in 2024 did not exceed PLN 200 million. For some of the smallest taxpayers, the obligation to issue invoices in KSeF will apply later, from 1 January 2027. At the same time, the Polish Ministry of Finance has announced that no sanctions will be imposed in 2026 for errors made while using the system during the transitional period.

However, the absence of sanctions for errors does not mean that businesses can focus only on the technical import of documents. On the contrary, this is exactly the moment to organise the invoice workflow and approval process before incorrect or unverified documents start reaching the accounting department. This is particularly important in companies where several people are responsible for purchasing, approving costs and forwarding documents for settlement.

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Why scam invoices have become an issue in the National e-Invoicing System in Poland (KSeF)

This issue is not just a market phrase or an informal label. The Polish Ministry of Finance itself uses the term scam invoices and has announced that the option to report them in the KSeF Taxpayer Application 2.0 will be simplified. At the same time, in materials addressed to system integrators, the Ministry indicates that the functionality for reporting scam invoices and hiding invoices will continue to be developed in subsequent versions of the system.

This is an important signal for businesses. If the tax administration is developing separate functions for these documents, that means companies need a real review stage after an invoice is received. The fact that a document appears in KSeF should not be treated as automatic confirmation that it is ready to be posted.

Why retrieving an invoice from the National e-Invoicing System in Poland (KSeF) is not enough

The KSeF Taxpayer Application 2.0 is the official free tool provided by the Polish Ministry of Finance. It allows users to issue, receive and review invoices that comply with KSeF 2.0 requirements. The Ministry also emphasises that the application allows invoices to be searched and downloaded in XML or PDF format. This alone shows that, after receipt, there is meant to be a review and assessment stage rather than fully automatic processing.

In practice, the entrepreneur should answer at least a few key questions. Does the invoice actually relate to the company? Does it reflect a real transaction? Are the buyer’s details and amounts correct? Should the document already be forwarded for accounting?

KSeF organises the technical flow of the document, but it does not know the company’s internal cost approval rules, does not confirm whether the invoice matches an order and does not decide whether the document requires additional clarification. That remains the responsibility of the business.

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Which documents require particular caution

In practice, three groups of documents require special control.

Invoices issued by mistake

These are situations where a document has been issued incorrectly, addressed to the wrong entity or contains incorrect data. Such an invoice may appear in the system, but from the company’s perspective it should not automatically be included in settlements without prior review.

Scam invoices

These are documents that raise doubts as to whether they should be accepted at all and require a reaction on the part of the entrepreneur. Since the Ministry of Finance provides a separate reporting path for them and is continuing to develop this functionality, it is reasonable for an organisation to have its own internal process for identifying such cases.

Documents requiring a business decision

Not every invoice is immediately ready to become an accounting document. Some require confirmation from the purchasing department, the person responsible for a contract or the manager approving the expense. Only after that verification can the document be safely forwarded for posting.

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A token in the National e-Invoicing System in Poland (KSeF) is technically important, but it does not replace invoice control

Many companies tend to equate a properly functioning integration with full process security. That is too broad a simplification. A token in KSeF plays a technical role and concerns authentication and access to the system. The Polish Ministry of Finance has also clarified that tokens generated in KSeF 1.0 are not compatible with KSeF 2.0, and that generating new tokens has been possible since 1 February 2026.

This means the token is necessary on the system side, but it does not solve the substantive review problem. It does not replace expense approval, does not confirm that the transaction is correct and does not decide whether the invoice should be posted to the books.

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How to organise invoice control in practice

The safest model is to separate three stages: receipt of the document, its verification and its transfer for accounting. In practice, it is worth organising the process so that, once an invoice has been retrieved from KSeF, the company can:

• assign the document to the right person or department,
• check whether the invoice relates to a real transaction,
• assess whether the document is correct and complete,
• stop any document that raises doubts,
• approve only those invoices that should actually be settled.

This approach reduces the risk that an unverified, incorrect or unclear document will be posted to the accounting books.

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Polish Ministry of Finance tools versus business needs

The free tools provided by the Polish Ministry of Finance are an important part of KSeF implementation and, for some businesses, may be sufficient for basic handling. The KSeF Taxpayer Application 2.0 allows users to issue, receive, review and search invoices, as well as download them in XML and PDF formats.

In many organisations, however, a broader working model is needed. Beyond simply receiving documents, businesses often require a structured process for reviewing, approving and forwarding them to accounting. This is especially relevant for companies that want to combine compliance with KSeF in Poland with better document workflow management and lower operational risk.

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Customer Invoice Portal as an additional level of control

In response to the growing importance of document control in the KSeF environment, getsix® is developing Customer Invoice Portal as a tool that supports a more structured workflow for invoices and other accounting documents.

The solution is designed not merely to transfer documents technically, but to support the entire handling process, from adding or retrieving a document, through review and verification, to final approval before posting.

From the entrepreneur’s perspective, this has clear practical value. Customer Invoice Portal helps separate the mere retrieval of a document from KSeF from the decision as to whether that document should be passed on for accounting. This is particularly important for businesses that want greater control over document circulation, a lower risk of errors and a more organised cost approval process.

The portal supports this process through:

• handling documents related to KSeF as well as documents outside the system,
• work in one consistent environment,
• better process transparency and easier status tracking,
• the ability to add notes to documents,
• improved cooperation between people involved in the document workflow.

As part of cooperation with getsix®, Customer Invoice Portal is available in two options:

• Free package – the user uploads documents manually and decides which invoices should be passed on for further handling,
• Standard package – this includes automatic import of invoices from KSeF together with a review and approval stage before transfer to accounting.

As a result, Customer Invoice Portal can be a practical complement to accounting services in Poland for businesses that want not only compliance with KSeF, but also better control and organisation of their document workflow.

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KSeF does not end with system integration and e-invoice import. From a technical perspective, the system organises the issuing, receipt and storage of structured invoices, but it does not take over the entrepreneur’s responsibility for assessing whether a given document should actually be posted. In the reality of 2026, when the obligation to receive invoices through KSeF is already in force and the Polish Ministry of Finance is developing functionalities related to scam invoices, document control is no longer an optional extra. It is a necessary element of a safe and well-managed process.

That is why businesses should treat KSeF not only as a technology project, but also as an organisational change. The earlier a company structures its internal rules for invoice review, approval and transfer to accounting, the easier it will be to reduce the risk of errors, mistaken documents and irregularities in document circulation.

For this process to work smoothly in practice, it is worth combining KSeF integration with a solution that supports document control and approval, such as Customer Invoice Portal.

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If you have any further questions or require additional information, please contact your business relationship person or use the enquiry form on the HLB Poland website.

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