The Polish Ministry of Finance on 20 October 2021 issued a specification for the National e-Invoicing System (NeIS), providing tips for software developers wishing to integrate their programs with NeIS (API). This specification is not a source of law, but is only a set of guidelines for developers. The NeIS test environment website (https://ksef-test.mf.gov.pl/) does not contain a graphical user interface for uploading or downloading invoices. It contains material intended for IT departments working on integration with NeIS. This address is also used by the published API. The logical structures used by the API, the OpenApi (formerly Swagger) documentation and editor, and the test environment public key have been made available. For the time being, no descriptive interface specification has been published, as was the case for e-Declaration or the Single Control File. It has been indicated that the test version will use self-generated signatures and seals for authorisation in NeIS, the test version does not offer authorisation via the Trusted Profile and token at this point. Invoices will be submitted using the API provided in batch or interactive mode. An Official Delivery Certificate will be available with a list of invoices sent in a batch packet or during an interactive session. The provided service will verify the correctness of the sent invoices with the working version of the XSD schema. The API introduces permissions that can be assigned to a system user. A privilege management facility is provided that will allow to view, grant and revoke privileges. The types of roles available in the process are also indicated. It is worth noting that the message states that it is planned to make the use of e-Invoice mandatory for entrepreneurs in Poland from 2023.
PEPPOL Access Points are e-invoicing solution providers who offer services fully compliant with the PEPPOL Network requirements. If a company is a certified PEPPOL Access Point, all clients can exchange their electronic documents with other participants of the network. In practice, a supplier using an Access Point sends documents to the recipient. The Access Point, responsible for correct document transmission, is obliged to ensure compliance with the PEPPOL specifications. The document is sent to the recipient’s Access Point in charge of document translation for its client. Both buyers and suppliers are free to choose their Access Point provider.
Structured e-invoices contain core system elements that are compliant with legal regulations of different countries. Those elements are essential for enabling full interoperability during cross-border business operations.
PLATFORMS THAT IMPLEMENT THE E-INVOICING OBLIGATION IN B2G IN THE EU – DIRECTIVE 2014/55/EU
In Europe, the milestone made towards electronic invoicing is April 18, 2019, was the deadline for EU member states to implement Directive 2014/55/EU. As of this date, government entities are required, at least in the area of public procurement, to be ready to receive structured electronic invoices from their suppliers.
Instead of a restrictive or uncomfortable dictate imposed by a European central authority, public and private organizations of all sizes are finding that Peppol provides greater security, reduced costs and fewer manual processing errors.
What is the Central Register of Invoices and the National e-Invoice System
Poland as the fourth country of the EU countries decided to introduce the Central Invoice Register as another mechanism to prevent fraud against VAT. The Central Invoice Register is also known as the Central Invoice Database or the National e-Invoice System. It is a system that brings together all the invoices issued by entrepreneurs. It was established in order to tighten the tax system and prevent tax fraud. The Polish National e-Invoice System began its operation on 1 January 2022 under the Act of 29 October 2021 amending the Act on Value-added Tax and certain other acts (Journal of Laws of 2021, item 2076). The National e-Invoice System (NeIS) allows structured invoices to be issued and made available. On the basis of Art. 106nb of the Act on Value-added Tax of 11 March 2004, NeIS can be used by taxpayers, entities indicated by the taxpayer (e.g. an accounting office), enforcement bodies specified in the Act on Enforcement Proceedings in Administration of 17 June 1966 and court bailiffs performing enforcement actions within the meaning of the provisions of the Code of Civil Procedure in cases indicated in Art.106c of the VAT Act, natural persons indicated by such entities, natural persons indicated in the notice on granting or withdrawing the right to use the National e-Invoice System to whom the taxpayer or entities referred to in Art. 106c of the VAT Act have granted the right to use this system, entities other than listed, indicated by natural persons using the National System for e-Invoices, if the right to indicate another entity results from the rights granted to such natural persons.
In January 2022 there have entered into force the provisions of the Polish law on special rules for the remuneration of persons performing tasks in the field of cyber security, which, among other things, provide for the creation of the Polish Cyber Security Fund, which will be used to finance salary supplements for persons engaged in cyber security.
HIGHER EARNINGS OF SPECIALISTS WORKING FOR MAJOR OFFICES IN POLAND
ICT benefit, which is a salary or emoluments allowance, is to be provided to persons performing tasks in a national level CSIRT; in cybersecurity authorities; persons who serve the Plenipotentiary for Cyber-security, as well as persons who perform tasks related to ensuring cyber-security in, among others, the Internal Security Agency, the Foreign Intelligence Agency, the Central Anti-Corruption Bureau, organizational units subordinate to the Prime Minister or to ministers, the Chancellery of the Prime Minister or in offices serving ministers, the Police or the State Protection Service.
The amount of remuneration for the work, including the ICT benefit, cannot exceed twenty-one times the base amount for members of the civil service corps specified in the Budget.
