Alignment of 2026 foreign VAT refund procedures with the country’s KSeF mandatory e-invoicing regime
A draft regulation published by the Ministry of Finance would require foreign businesses claiming Polish VAT refunds to reference KSeF invoice identification numbers in refund applications wherever available. The changes are intended to modernise the refund process and connect it directly to Poland’s structured e-invoicing platform.
For EU-established businesses, refund applications submitted through their domestic tax authorities would need to include the KSeF invoice reference numbers for qualifying purchases. Where KSeF references are unavailable, invoice copies, including electronic invoices, must instead be provided.
Non-EU businesses would face similar obligations. They would also need to provide KSeF references where possible, or alternatively submit supporting invoice documentation directly to the Polish tax office alongside the claim.
Transitional measures for 2026
The proposed rules introduce transitional measures. Refund claims relating to periods before 1 January 2026 would continue under the current regime. Claims covering periods from 2026 onwards may fall within the new documentation rules depending on when the application is submitted and when the regulation formally enters into force.
The move is another example of how Poland’s KSeF framework is extending beyond domestic invoicing compliance into wider VAT administration and audit processes.
