Housing communities invoice in KSeF too

The Polish VAT Act does not exempt housing communities from KSeF (Krajowy System e-Faktur, Poland's national e-invoicing system): the list of exclusions in art. 106ga(2) mentions neither a wspólnota mieszkaniowa (the owners' association of a block of flats) nor a housing cooperative. When a community issues an invoice to another taxpayer, it does so in KSeF (art. 106ga(1)), even if it is exempt from VAT. Until 31 December 2026 it may stay outside the system if it invoices no more than 10,000 PLN gross in a given month.

Legal position as of 2 November 2026.

Why a housing community is in KSeF like any other taxpayer

In the KSeF 2.0 Handbook (part II, point 1.2), the Ministry of Finance (MF) lists among taxpayers "another entity that is not a natural person, e.g. a foundation, a housing community or an association". According to MF, three conditions decide whether an activity makes someone a taxpayer: independence, continuity and a gainful character. The list shows who can be a taxpayer. It does not mean every community is one for every transaction.

MF: KSeF 2.0 Handbook, part II, point 1.2

If a community is a taxpayer and issues an invoice, the same deadlines apply to it as to everyone else: since 1 April 2026 the duty to invoice in KSeF covers taxpayers whose 2024 sales did not exceed 200 million PLN gross. A VAT exemption does not change that. The MF FAQ says that "as a rule, every taxpayer (active and exempt) that is obliged to issue an invoice will issue it in KSeF".

MF KSeF 2.0 FAQ: active and exempt taxpayers in KSeF

When a community does not issue the invoice in KSeF

An invoice to an owner who is a private individual does not have to go through KSeF. Art. 106ga(2)(4) excludes invoices to natural persons who do not run a business. The community may still issue such an invoice in KSeF voluntarily (art. 106ga(4)), and the owner then receives it in an agreed way, with a QR code. The details are in our post on invoices for private persons. An invoice to an owner who runs a JDG (jednoosobowa działalność gospodarcza, a sole trader business) is also voluntary in KSeF if it concerns a purchase for private use: according to the MF FAQ, that is in essence a B2C transaction.

VAT-exempt sales need an invoice only on request. Art. 106b(2) lifts the duty to invoice exempt sales, among others those exempt under art. 43(1) or art. 113(1). An invoice must be issued when the buyer asks for it within 3 months from the end of the month in which the goods were delivered or the service performed, or in which all or part of the payment was received (art. 106b(3)(2)). If that invoice is for another taxpayer, the community issues it in KSeF. A plain bill (rachunek) is no substitute: the MF FAQ answers that exempt transactions are documented "with an invoice issued at the buyer's request, not with a bill".

Accounting notes stay outside KSeF. According to the Handbook (part II, point 1.1), debit and credit notes and pro forma invoices, among others, do not go into the system. The MF FAQ adds that notes may still be used, "but they will not be issued in KSeF". When a note can replace an invoice is not covered there.

Until the end of 2026 the 10,000 PLN limit applies (art. 145m). A community may issue paper or electronic invoices outside KSeF if their total gross value in a given month is no more than 10,000 PLN. Invoices to private individuals do not count towards the limit. If in November 2026 a community invoices businesses for 6,000 PLN and 5,000 PLN gross, the second invoice breaks the limit. The community issues that invoice and every later one, in the following months too, in KSeF (art. 145m(2)). From 1 January 2027 the limit is gone, as we explain in the end of the 10,000 PLN limit.

VAT Act, arts. 106b, 106ga(2) and (4), 145m (Dz.U. 2026 item 1263)

The art. 106ni penalties for an invoice issued outside KSeF (up to 100% of the tax on the invoice, or up to 18.7% of the total amount due when the invoice shows no tax) apply under the Act from 1 January 2027. On 16 September 2026 MF announced a deferral of the penalties to the end of 2027, and government bill UD477 (Sejm print no. 3245) moves them to 1 January 2028. The Sejm is due to take it up at its sitting of 5–6 November 2026. The bill has not been passed, so the 2027 date is the one in force today.

MF: penalty deferral extended to end of 2027

How a community receives invoices for electricity and from contractors

A purchase invoice reaches the community in KSeF when the seller enters the community's NIP (tax ID) in the buyer's NIP field. If the seller puts it in another field (such as the EU VAT number), the community does not get the invoice in the system. The invoice counts as received on the day KSeF assigned it a number (art. 106na(3)). A community without a NIP receives invoices in a way agreed with the seller (art. 106gb(4)).

MF: KSeF 2.0 Handbook, part II, points 1.6.4, 1.6.5 and 5.1–5.3

For anyone to see those invoices, the community needs access to KSeF. An entity that is not a natural person logs in with a qualified electronic seal or files a ZAW-FA notification (the form that names who gets initial KSeF access). ZAW-FA names exactly one natural person, who does not have to be listed in the KRS (National Court Register). That person gets, among other rights, permission to manage permissions, issue invoices and access them. You can file ZAW-FA(3) on paper, through e-Urząd Skarbowy (the tax administration's online portal) or through e-Doręczenia (the official e-delivery service). Since 1 January 2026 a notification sent through ePUAP is not effective.

KSeF regulation, Dz.U. 2025 item 1815, § 5(1) and (3) MF: ZAW-FA(3) form in e-Urząd Skarbowy

That person then grants permissions electronically to other people or to another entity, such as an accounting firm, which can then issue and view the community's invoices. We found no separate description in the MF materials of access for a property manager. The same mechanisms as for an accounting firm can be used (Handbook part I, pp. 20, 22 and 58–61).

An example: Pani Krystyna runs a one-person accounting office and keeps the books for the housing community on Lipowa Street. A member of the community's board, named in ZAW-FA, grants her office permission to view invoices. Once the permission is active, Pani Krystyna downloads from KSeF the invoices from the electricity supplier and from the company repairing the roof.

MF: KSeF 2.0 Handbook, part I, pp. 20, 22 and 58–61

Our guide to KSeF access for your accountant shows step by step how to grant that permission, and the guide to receiving invoices in KSeF shows where to find the invoices afterwards.