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Issuing and receiving invoices

Cash register invoices and NIP receipts in 2027

6 min read

Until 31 December 2026, invoices issued with a cash register (kasa rejestrująca) and receipts carrying the buyer's NIP up to PLN 450 (EUR 100) can stay outside KSeF (art. 145n of the VAT Act). From 1 January 2027 a cash register can no longer issue invoices and a receipt with a NIP stops being a simplified invoice, so a business that wants an invoice gets it in KSeF.

KSeF 2.0 Handbook, part I, p. 14

Legal status as of 7 October 2026.

What changes at the till

DocumentUntil 31 Dec 2026From 1 Jan 2027
Invoice issued by the cash registerOutside KSeF, paper or electronicThe register issues no invoices
Receipt with NIP up to PLN 450 / EUR 100Simplified invoice (art. 106e ust. 5 pkt 3)Plain receipt, not an invoice
Receipt for a private customerNo changeNo change

From 2027 a cash register user issues and hands the buyer only a fiscal receipt (art. 111 ust. 3a pkt 1, in the wording that applies from 1 January 2027). Sales to private individuals are still recorded on the register (art. 111 ust. 1), and receipts themselves never go to KSeF, because the system handles invoices only.

MF FAQ: invoices previously issued on cash registers

A business customer asks for an invoice: what you do in 2027

Take a bicycle shop and Ania, a freelance designer with a sole proprietorship, who buys a monitor for PLN 380 gross on 12 January 2027. Until the end of 2026 a receipt with her NIP would have been the invoice. In 2027 it goes like this:

  1. She gives her NIP at the till, before the receipt is printed. An invoice to a taxpayer for a cash-register sale can be issued only if the receipt contains the buyer's NIP (art. 106b ust. 5). An invoice issued in breach of this means an additional tax liability of 100% of the VAT shown on it (ust. 6).
  2. The seller issues the invoice in KSeF, in their software or in the free Taxpayer Application (Aplikacja Podatnika). They have until the 15th of the following month (art. 106i ust. 1), here 15 February, so it does not have to happen at the counter.
  3. Ania collects the invoice in KSeF. It counts as received once the system assigns it a KSeF number, with no acceptance by the buyer. The seller and buyer agree on how to deliver an invoice outside KSeF (e.g. as a PDF) only in special cases, for example invoices to consumers or foreign recipients.
  4. The seller keeps the link to the receipt: the document number and the register's unique number, or the paper receipt, together with data identifying the invoice (art. 106h ust. 1). Until the end of 2026 this did not apply to cash-register invoices (art. 145n ust. 3).

A seller exempt from VAT, such as a hairdresser, still issues an invoice only at the buyer's request (art. 106b ust. 2 and 3). If a business asks, the invoice goes through KSeF on the same terms as for everyone else.

VAT Act, consolidated text Dz.U. 2026 item 1263 MF FAQ: delivering an invoice outside KSeF (Q11)

A private customer asks for an invoice

Invoices to individuals who do not run a business are outside the KSeF obligation (art. 106ga ust. 2 pkt 4). You can issue one in KSeF voluntarily, including for a receipt, or the old way on paper or electronically. The customer can ask for it up to 3 months after the end of the month of the sale (art. 106b ust. 3). Keep one numbering sequence for both kinds: KSeF does not impose it, but continuity and chronological order still apply.

MF FAQ: B2C invoices and numbering

What to set up before January

  • Invoicing tool. If a register issues your invoices after receipts today, from January you need software integrated with KSeF or the Taxpayer Application. The PLN 10,000 threshold also stops applying from 2027, so invoices to businesses go through KSeF whatever the monthly amount.
  • Access. A sole trader gets owner permissions in KSeF assigned automatically to their NIP, with no notification to the tax office. KSeF 2.0 Handbook, part I, section 3.2.1, p. 57 People who are to issue invoices on their behalf get permissions separately. The basics are in KSeF for sole traders and the preparation checklist.
  • Till routine. Staff ask for the NIP before the receipt prints and know the invoice will follow from KSeF.
  • Your accountant. Until the end of 2026 a cash-register invoice whose sale is already in the daily report does not increase sales or tax (art. 145n ust. 4). We found no equivalent rule for 2027 in the Act or in MF sources. Ask your accountant how to record a KSeF invoice for a sale already registered on the cash register in your JPK. We also found no MF guidance on how to show the receipt number in the FA(3) structure.

From 1 January 2027 the Act provides penalties for not issuing an invoice in KSeF: up to 100% of the VAT on the invoice, or up to 18.7% of the gross amount where no VAT is shown (art. 106ni ust. 1). On 16 September 2026 the MF announced a deferral of penalties to the end of 2027, and draft UD477 moves them to 1 January 2028. It is still a draft, not law.

MF: extension of the penalty deferral to the end of 2027 Draft UD477 (RCL)