KSeF does not change the rules for using commercial invoices in exports

A commercial invoice used for customs purposes does not have to go through Poland’s mandatory National e-Invoicing System, according to a ruling by the director of the National Tax Information service.

The authority confirmed that such a document is not an invoice within the meaning of Poland’s VAT law. It therefore remains outside the mandatory KSeF system, a position that is important for companies engaged in international trade.

The ruling also addressed export documentation. The IE/CC599C message may confirm a company’s right to apply a zero VAT rate even when it contains the number of a commercial invoice rather than the number of a VAT invoice.

The individual interpretation, issued on July 10, 2026, concerned a Polish company belonging to an international corporate group. As part of an effort to standardize its export procedures, the company planned to separate its tax documentation from its customs documentation. In practice, that meant issuing two documents for the same export transaction: a VAT invoice for tax settlement and a separate commercial invoice used exclusively for customs declarations.