Split payment mechanism and KSeF invoices in Poland – what changes for businesses?

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Split payment and KSeF invoices in Poland

From 1 January 2027, payments for structured invoices issued through the National e-Invoicing System (KSeF) in Poland will require closer attention to invoice identification data. For payments made under the split payment mechanism, businesses will need to correctly indicate either the KSeF invoice number or the collective identifier.

KSeF does not change the basic principles of split payment in Poland. The key factors remain the Polish VAT Act, the invoice value, the status of the parties and the type of goods or services purchased. What changes is the technical link between the payment and the structured invoice.

For companies operating in Poland, preparation for KSeF should therefore include payment procedures, accounting systems, invoice approval workflows and online banking processes.

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When is split payment mandatory?

The split payment mechanism divides the payment into two parts:

• the net amount is transferred to the supplier’s settlement account or settled in another permitted way,
• the VAT amount is transferred to the supplier’s dedicated VAT account.

Split payment may be used voluntarily, but it is mandatory when all of the following conditions are met:

• the invoice documents a transaction between taxpayers,
• the total amount due exceeds PLN 15,000 or its equivalent,
• the invoice covers goods or services listed in Annex 15 to the Polish VAT Act.

If these conditions are met, the invoice should include the wording “mechanizm podzielonej płatności”. However, the buyer should not rely only on the seller’s marking. The absence of this wording does not always release the buyer from the obligation to apply mandatory split payment.

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Invoice number, KSeF number and collective identifier

Businesses may have to deal with several identifiers for the same invoice: the invoice number assigned by the seller, the number identifying the invoice in KSeF and, for collective payments, the collective KSeF identifier.

The KSeF number is not the same as the invoice number used in the seller’s accounting system. It is assigned by the National e-Invoicing System after the structured invoice is accepted and serves as the technical identifier of the document.

When paying a single structured invoice using split payment, the transfer message should generally include the VAT amount, gross amount, seller’s Tax Identification Number (NIP) and the KSeF invoice number. If the payment covers only part of the amount due, the values in the message should correspond to the part being paid.

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Collective split payment for KSeF invoices

The Polish VAT Act allows several invoices to be paid with one split payment transfer if one supplier or service provider issued more than one invoice within a period of not less than one day and not more than one month.

For structured invoices issued through KSeF, a collective payment may cover selected invoices from one supplier within that period. The business does not have to include all invoices from that supplier. Instead of entering individual invoice numbers or a payment period, the transfer message should include the collective KSeF identifier.

This identifier aggregates the KSeF numbers of the invoices included in the payment. It will be particularly important for companies that receive many invoices from the same suppliers, make recurring payments or use collective payments for purchase invoices.

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What should the buyer verify?

Before paying a KSeF invoice, the buyer should check:

• whether the invoice value exceeds PLN 15,000,
• whether the invoice covers goods or services from Annex 15,
• whether the payment concerns one invoice, part of an invoice or several invoices,
• whether the KSeF number or collective identifier should be used,
• whether the VAT amount in the transfer message matches the payment covered by split payment.

The split payment mechanism has been extended until 2028, so businesses should treat it as a permanent element of VAT and payment processes in Poland. In the KSeF environment, the key practical issue will be the consistency of data between invoices, accounting systems, online banking and VAT records.

Read the full article here: Split payment mechanism and KSeF invoices in Poland – what changes for businesses?

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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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