KSeF and B2C, Proforma and Accounting Notes — What Is Not Issued Through the System?
So many misconceptions have built up around KSeF that they could fill an entire filing cabinet. One of the most common is the belief that "everything will have to go through KSeF". In practice, not every document is subject to the system.
That is why it is worth clearly separating what falls under KSeF and what does not.
Do B2C Invoices Have to Be Issued Through KSeF?
No. Invoices for consumers — meaning private individuals who do not run a business — are not subject to mandatory KSeF.
This is one of the most important facts for companies that:
- sell services to private individuals,
- operate in e-commerce,
- have a mixed B2B and B2C sales model.
Issuing B2C invoices through KSeF remains voluntary.
Do B2C Invoices Count Towards the 10,000 PLN Threshold?
Not in the way often assumed.
Under the transitional simplification for the smallest businesses, the 10,000 PLN monthly threshold applies only to the value of invoices that the taxpayer is obliged to issue through KSeF. Consumer invoices are not subject to mandatory KSeF, so they should not be mechanically bundled into the same calculation.
Is a Proforma Invoice Issued Through KSeF?
No. A proforma invoice is not a VAT invoice within the meaning of the VAT Act, so it is not issued through KSeF.
This is important for businesses that:
- first send the client a payment request document,
- only issue a proper invoice after payment is received,
- have a sales process built around deposits and pre-invoice documents.
Does an Accounting Note (Nota Księgowa) Go Through KSeF?
No. An accounting note is not a document issued through KSeF.
For many business owners this is a practical relief — it means that not all auxiliary and settlement documents suddenly have to be routed through a single government system.
Why Is Distinguishing Between Document Types So Important?
Because incorrectly assuming that "everything goes through KSeF" can lead to:
- misconfiguration of software,
- chaos in document workflows,
- incorrect internal procedures,
- unnecessary accounting work,
- problems during implementation.
In practice it helps to maintain a simple table:
- documents mandatory in KSeF,
- documents optionally in KSeF,
- documents outside KSeF.
KSeF and Mixed B2B/B2C Sales
If you sell to both businesses and private individuals, separating the two processes correctly is especially important. Some documents will be subject to the mandatory workflow, others will not.
This means your sales and accounting system should be set up to:
- correctly identify the type of buyer,
- not send to KSeF documents that should not be there,
- handle different scenarios without manual workarounds.
Key Takeaway
KSeF does not cover everything. B2C invoices are outside mandatory KSeF, a proforma is not an invoice, and an accounting note is also not a document issued through the system.
If you run a business operating across several sales models, getting these concepts straight is absolutely essential. Without this clarity, even the best software starts to resemble an office escape room.
Tax and e-invoicing rules in Poland change frequently. Always verify current requirements with a licensed accountant or at podatki.gov.pl.