AutoSmart GuidebooksWhat 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 2027 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
Open a standard to see the law behind it, what is checked, what it can cost and the evidence. Ideal fix times are counted from audit submission.
VAT-01Invoices in KSeF30 days
- The law
- VAT Act · KSeF · Excise Duty Act · mandatory National e-Invoice System (from 2026)
- What we check
- All B2B invoices are issued in KSeF in the FA(3) schema, and the DMS is integrated with KSeF.
- What it can cost
- From 2027, a fine of up to 100% of the invoice's VAT.
- Evidence
- KSeF report
VAT-02Split payment on parts7 days
- The law
- VAT Act · KSeF · Excise Duty Act · split payment mechanism: Annex 15 (vehicle parts)
- What we check
- Invoices for car parts and accessories above PLN 15,000 gross carry the note "split payment mechanism" and are paid by split payment.
- What it can cost
- A 30% VAT sanction and joint and several liability.
- Evidence
- Invoices
VAT-03Excise on cars30 days
- The law
- VAT Act · KSeF · Excise Duty Act · excise on passenger cars (3.1% / 18.6%, rates for hybrids)
- What we check
- On import and intra-EU acquisition of passenger cars, excise is declared and paid on time at the right rate.
- What it can cost
- The arrears with interest, and liability under the Fiscal Penal Code.
- Evidence
- Excise returns
VAT-04JPK_VAT and GTU codes7 days
- The law
- VAT Act · KSeF · Excise Duty Act · JPK_VAT with the return · GTU codes (for example GTU_07 for vehicles and parts)
- What we check
- JPK_VAT is filed every month, and vehicles and parts carry the right GTU codes.
- What it can cost
- PLN 500 for each error, plus Fiscal Penal Code penalties.
- Evidence
- UPO receipts
VAT-05B2B cash payment limit7 days
- The law
- VAT Act · KSeF · Excise Duty Act · Entrepreneurs' Law art. 19: payments above PLN 15,000 through a bank account
- What we check
- Payments between businesses above PLN 15,000 are made by bank transfer, not in cash.
- What it can cost
- The customer loses the tax-deductible cost.
- Evidence
- Cash reports
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.
