KSeF and your accountant: agree who does what

Once you give your accounting office permission to access invoices in KSeF (Krajowy System e-Faktur, Poland's National e-Invoicing System), the office downloads all your sales and purchase invoices from the system itself, so you no longer need to send them. You only supply documents that aren't in KSeF. Invoices are issued by whoever you give the issuing permission to: you, the office, or both.

Legal position as of 26 October 2026.

How does MF describe splitting the work with an office?

In part I of the KSeF 2.0 Handbook, the Ministry of Finance (MF) describes three models and notes that they "differ in the scope of each party's responsibility". KSeF 2.0 Handbook, part I, p. 20

Ania, a graphic designer running a JDG (jednoosobowa działalność gospodarcza, a Polish sole proprietorship), issues three invoices a month in her own software. Model 2 suits her best: she issues the invoices herself, and Krystyna at the office downloads both her sales and her purchases from KSeF. Model 3 makes sense if you don't want to issue invoices yourself or have no internet access. MF names the second reason explicitly: in that case you can give the issuing permission to, for example, someone at the office. KSeF 2.0 FAQ, question on people without internet access

Which permissions should the office get?

MF lists three permissions you can give to employees and to firms you work with: issuing invoices, viewing invoices and managing permissions. MF: leaflet “Pracownicy i Księgowi”

• Viewing invoices (called "invoice access" in the KSeF Handbook) covers all your invoices, sales and purchases alike. You can't limit it to purchases only.
• Issuing invoices is a separate permission. It also covers issuing in the offline modes (offline24, unavailability, emergency mode). You can grant one without the other. KSeF 2.0 Handbook, part I, pp. 54-55
• Managing permissions lets someone grant and revoke access on your behalf. You can't give it to the office as a firm, only to a named person. Bookkeeping doesn't need it, so keep it for yourself. Taxpayer Application manual, section 5.5.2.7, table 32

You grant a permission either to the office as a firm, by its NIP, or to a specific accountant. If you grant it to the office and tick "z prawem do dalszego przekazywania uprawnienia" (with the right to pass the permission on), the office picks the staff who handle your account itself, and you don't have to do anything when its staff change. KSeF 2.0 FAQ, question on office employees As a JDG you do this electronically, in the KSeF Taxpayer Application (Aplikacja Podatnika KSeF) or in software connected to KSeF, without filing a ZAW-FA notification. The steps are in our guide on how to give your accountant access to KSeF.

Can an office that issues for you cope with an outage?

The issuing permission covers the offline modes, so the office can issue an invoice even when KSeF is down. An offline invoice handed over outside KSeF must carry a QR code, and generating it requires a type 2 KSeF certificate. Certificates issued to a person may not be shared, so in the MF example the accountant uses her own certificate when issuing offline. KSeF 2.0 Handbook, part I, p. 48 (example 18)

So agree with the office who issues offline invoices during an outage and who then keeps track of the deadline for sending them to KSeF. The deadlines for each mode are in our guide to KSeF outages and offline mode. An offline invoice gets its KSeF number only once it is sent, and until then it isn't in the system.

What do you still need to send the office?

The office sees in KSeF only what has reached KSeF. You supply the rest as before: by e-mail, through software or in a binder.

• Your invoices to private individuals, if you issue them outside KSeF. An invoice to a consumer doesn't have to go into the system, although it may (art. 106ga ust. 2 pkt 4 and ust. 4 of the VAT Act).
• Invoices from foreign sellers with no registered office or fixed establishment in Poland (art. 106ga ust. 2 pkt 1 and 2), for example for software or advertising.
• Single-journey tickets (rail, bus, air) and simplified motorway toll invoices (art. 106ga ust. 2 pkt 5, regulation Dz.U. 2025 item 1740, § 2).
• Invoices issued outside KSeF until 31 December 2026: within the 10,000 PLN monthly limit (art. 145m), from a cash register, and receipts with a NIP treated as invoices (art. 145n). This applies both to your sales and to your purchases from such sellers.
• Documents that aren't invoices in KSeF: pro forma invoices, debit and credit notes (noty obciążeniowe i uznaniowe), internal documents. KSeF 2.0 Handbook, part II, section 1.1, p. 6

VAT Act, art. 106ga, 145m and 145n

For a purchase invoice from outside KSeF, the date of receipt is the day it actually reached you. That's why the office needs not only the file but also the date you got it. We explain how this affects VAT deduction in our post on deducting VAT from an invoice outside KSeF.

Who deals with a wrong or unknown purchase invoice?

KSeF has no "reject" button and sends no notifications about new invoices. The software used by the office or by you has to check for new arrivals itself. KSeF 2.0 Handbook, part II, sections 6.3-6.4 If the office downloads invoices once a month, it will only see an unknown invoice when it closes the period.

Only the seller can fix a wrong invoice, with a corrective invoice. Corrective notes (noty korygujące) have been gone since 1 February 2026, so neither you nor the office can issue a note against someone else's invoice. If the seller entered your NIP by mistake, they issue a correction to zero and a new invoice to the right buyer. KSeF 2.0 Handbook, part II, sections 1.6.2-1.6.4 You are the one who contacts the seller, because the office doesn't know what you ordered.

Anyone with invoice access in your context can report a suspected fraudulent invoice in the Taxpayer Application, and that includes the office. According to MF, an ordinary mistake, a price dispute or a renewed subscription isn't abuse yet. KSeF 2.0 Handbook, part III, sections 7.1-7.2 What to do with such an invoice is covered in our post on fake invoices in KSeF.

What to put in your agreement with the office

MF doesn't publish a template for this agreement. We suggest that Krystyna and Ania write down a few things:

1. Which model you use and which permissions the office has (with or without the right to pass them on to staff).
2. Who issues invoices, and if it's the office, based on what data and how soon after you ask.
3. Who checks purchase invoices in KSeF and how often, and who approves an invoice from a new supplier.
4. How and by when you send the documents from outside KSeF listed above.
5. Who contacts the seller about a correction and who reports abuse.
6. Who issues offline invoices during an outage and makes sure they are sent to KSeF.
7. What happens to the permissions when the engagement ends.

The split of duties between you and the office comes from your agreement, not from the KSeF rules. If the office is to issue invoices for you, show that part of the agreement to a lawyer.

How to switch offices without leaving the old one access

When you end the engagement, revoke the office's permissions in the Taxpayer Application or in your software. Only someone with the right to manage permissions can do this, which usually means you as the owner of the JDG. MF FAQ, Q18 Once you revoke the office's permissions, all its employees lose access to your business at once: their permissions formally remain but stop working. KSeF 2.0 Handbook, part I, pp. 77-78 If you gave access to a specific accountant, you revoke hers separately. Her KSeF certificate stays valid, but it no longer works on your behalf.

You grant the new office its permissions from scratch. MF describes invoice access as access to all of the taxpayer's invoices (part I, p. 55), and we found no caveat limiting it to invoices from the date it was granted. Invoices don't disappear from KSeF when you change offices, because the system keeps them for 10 years from the end of the year they were issued. KSeF 2.0 Handbook, part II, section 1.6.3

Before you sign a new agreement, check the list of granted permissions in the Taxpayer Application to see who has access to your invoices today. If you haven't agreed a model with your office at all, start with our guide on how to receive an invoice in KSeF.