No invoices from cash registers in Poland from 2027

Poland plans to remove invoicing functions from fiscal cash registers from 1 January 2027, shifting mandatory B2B invoicing to KseF, especially in relation to issuing simplified invoices. Cash registers will no longer be used to issue invoices

Poland is preparing important changes to its fiscal cash register regulations as part of the continued implementation of the National e-Invoicing System (KSeF). The changes aim to separate the functions of fiscal cash registers from electronic invoicing, simplify tax reporting and support the digitalization of retail transactions. This is formalized via following regulation:

https://legislacja.rcl.gov.pl/projekt/12411852/katalog/13211700#13211700 

According to the Ministry of Finance's draft amendments to the Regulation on Cash Registers, fiscal devices will no longer be permitted to issue invoices from 1 January 2027. Their primary function will remain recording retail sales and issuing fiscal receipts, while invoices subject to mandatory electronic invoicing will be processed through KSeF.

This change will particularly affect retailers that currently use fiscal cash registers or fiscal printers to issue invoices directly at checkout.

Under the existing rules, which remain applicable until 31 December 2026, businesses can issue invoices using fiscal cash registers. Additionally, a fiscal receipt containing the buyer's Tax Identification Number (NIP), with a total value not exceeding PLN 450 (or €100 where applicable), can qualify as a simplified invoice.

From 1 January 2027, these receipts will no longer be recognized as simplified invoices. Businesses selling to other taxpayers will instead need to issue the required invoices through KSeF, even when the underlying transaction is recorded using a fiscal cash register.

However, ordinary fiscal receipts will continue to be issued.

Another important element of the proposed regulation concerns the digitalization of fiscal reporting.

Under the draft, certain fiscal settlement reports and aggregate reports would be prepared and provided to the tax administration exclusively in electronic form. This would reduce the reliance on traditional reporting procedures and support the electronic processing of fiscal information.

One of the greatest challenges for retailers and technology providers is the implementation schedule. The existing legal framework allows fiscal cash registers to issue invoices until 31 December 2026. From 1 January 2027, this option will no longer be available. Consequently, retailers must ensure that their sales systems operate according to the appropriate rules on either side of the deadline.

The key requirement is that fiscal devices and associated software comply with the applicable regulations when the new rules take effect.

In our opinion, separating fiscal receipts from electronic invoicing is a logical development in Poland's fiscalization framework. It should reduce duplication between cash register functions and KSeF and create a clearer division between retail sales registration and invoice processing.

A clear regulatory framework, timely technical specifications and practical implementation guidance will be essential to ensure that the transition does not disrupt retail operations.

Implementation impact and what the business should do

The planned changes will directly affect fiscal device manufacturers, POS software providers and retailers operating in Poland.

Businesses should focus on the following preparations:

- Review invoicing functionality: Identify where fiscal cash registers and POS applications currently generate invoices or simplified invoices.

- Prepare KSeF integration: Ensure that invoices subject to mandatory e-invoicing can be generated through compliant invoicing software.

- Review reporting capabilities: Assess the potential impact of new electronic fiscal reporting requirements, including historical data processing.

- Plan the transition: Prepare and test software updates before 1 January 2027 to avoid disruption at checkout.

- Monitor the final regulation: Follow the legislative process, particularly the technical reporting requirements and any transitional provisions.

The main priority is to ensure that POS systems and fiscal devices can continue recording sales correctly from 1 January 2027 while invoice issuance follows the new legal framework.

The source for this text above is based on an article published by VATUpdate. Source

Nikolina Basić, Senior Legal Consultant at Fiscal Solutions

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