Mandatory e-Invoicing System since 2024?

A long-awaited decision of the Council of the European Union, approving the mandatory National e-Invoicing System in Poland, has appeared in the EUR-Lex. Interestingly, unlike previously planned, according to this document, the System is to become mandatory on 1 January 2024, which is nearly one year later than initially planned.

The decision of the Council is temporary and covers the period from 1 January 2024 until 31 June 2026. However, after this period ends, Poland can apply for extension of the approval, provided that the electronic invoicing system contributes to counteracting VAT fraud and evasion of VAT, and that it simplifies tax collection.

The decision of the EU Council is quite brief and laconic. It repeats the standpoint expressed by the Commission that the mandatory electronic invoicing will be limited to taxable persons established in the territory of Poland Additionally, the decision does not mention the need to report intra-Community acquisition of goods or import of services in the electronic invoicing system. It seems that these and similar issues will only be provided for in the Polish Act implementing the mandatory e-invoicing system (at the moment only the Act on optional e-invoicing is in force).

Postponement of the date of entry of the mandatory electronic invoicing into force is good news for taxable persons. They will have more time to implement the relevant system. However, we recommend that this task should not be deferred until the last moment, because implementation of the system is a complex and time-consuming process and there are voices saying that the time remaining to the planned date of the system deployment (1 April 2023) could prove too short for some entities.

Should you have any questions or doubts regarding the issues discussed here, or if you need assistance in implementing the electronic invoicing system, you are welcome to contact us.


Aleksandra Kalinowska Partner, Warsaw

T: +48 22 690 08 70
M: +48 724 440 693

Elżbieta Lis Partner, Katowice

T: +48 32 731 68 58
M: +48 664 948 038

Natalia Pielka Senior Consultant, Warsaw

T: +48 22 690 08 88