What this guidebook covers
Every car and every part is a transaction in KSeF, the National e-Invoicing System. From 2026, B2B invoices must go through KSeF, car parts above PLN 15,000 fall under split payment (MPP), and imported cars carry excise duty. Missing split payment on parts costs a 30% VAT sanction, and from 2028 an invoice outside KSeF can cost up to 100% of its VAT.
This guidebook covers 5 tax standards for dealers, with 11 checkpoints: invoices in KSeF, split payment on parts, excise on cars, JPK_VAT files and GTU codes, and the B2B cash payment limit. The guidebook PDF is in Polish.
The 5 tax standards
| Code | Standard | Ideal fix time |
|---|---|---|
| VAT-01 | Invoices in KSeF | 30 days |
| VAT-02 | Split payment on parts | 7 days |
| VAT-03 | Excise on cars | 30 days |
| VAT-04 | JPK_VAT and GTU codes | 7 days |
| VAT-05 | B2B cash payment limit | 7 days |
How to run a Polish VAT, KSeF and excise audit, step by step
- Confirm what applies. Check the KSeF start date for each company (1 February 2026 for large firms, 1 April 2026 for the rest); the KSeF timetable has changed several times, so follow current Ministry of Finance announcements.
- Walk the site, standard by standard. Score each of the 11 checkpoints Pass, Fail or N/A. N/A only where the standard rules it out, with the reason recorded. Compare the sales register with KSeF, check 20 parts invoices for the split payment note and 10 car imports for the excise rate, and review JPK_VAT receipts (UPO) and the cash desk.
- Capture the evidence. A pass counts only with proof captured at the time of the audit: the KSeF report, parts invoices, excise returns, UPO receipts and cash reports.
- Give every fail an owner and a fix time. Record what you saw and who owns the fix. Each standard carries an ideal fix time, from 7 days to 30 days, counted from audit submission (see the table above).
- Fix it, then prove it. The site fixes the cause and uploads proof of closure; the auditor checks the proof before closing the finding.
- Re-check at the next audit. Confirm closed findings stay closed, and look for the same fail at your other sites so one gap doesn't repeat across the network.
Who this guidebook is for
- Boards and CFOs: planning KSeF and the risks
- Accounting: invoices, JPK and excise
- Auditors: invoices and split payment to check
A reference document, not legal advice. Fines and rules change: check the current text with the regulator or your legal adviser before acting.
