Polish VAT regulations allow invoices to be issued in foreign currencies, provided that the VAT amount is expressed in Polish zloty (PLN). This practice is especially relevant for foreign companies, contractors, and entities operating in Poland without a fixed place of business. Understanding how to issue invoices in foreign currencies and comply with Polish tax law is essential for businesses providing goods or services in Poland.
Invoice Issued in Foreign Currency – Legal Basis
According to the Polish VAT Act, an invoice can be issued in any foreign currency, as long as the VAT amount is converted into PLN using the average exchange rate of a given foreign currency announced by the National Bank of Poland (NBP). The exchange rate should be based on the last working day preceding the day the invoice is issued.
Key Rules for Issuing Invoices in Foreign Currencies
- VAT Must Be in PLN: Even if the invoice is issued in a foreign currency, the VAT must be shown in PLN.
- Exchange Rate: The rate of a given foreign currency announced by the NBP on the day preceding the invoice date is used for conversion.
- Structured Invoices and KSeF: With the mandatory use of the National e-Invoicing System (KSeF), structured invoices issued in foreign currencies must also comply with electronic invoice requirements.
Table 1: Key Elements of a Foreign Currency Invoice in Poland
| Element | Requirement |
| Currency | Any foreign currency |
| Exchange Rate | Average rate from NBP, last working day before the invoice date |
| | Storage | Must be stored electronically in accordance with KSeF |
| Applicability | All businesses including foreign entities without a fixed place in Poland |
KSeF and Invoices for Foreign Entities
As of February 2026, the use of the KSeF (Krajowy System e-Faktur) is mandatory for all VAT taxpayers in Poland. This includes, according to art. 106ga of Polish VAT Act., also foreign companies having fixed establishment in Poland (although the compliance of this Polish regulation with the provisions of the EU Directive is debatable). All invoices issued in a foreign currency must be submitted via the KSeF if the seller is subject to this system.
Foreign taxpayers must ensure that they issue invoices in accordance with Polish VAT law, particularly if they supply goods or services within Poland. Electronic invoices issued through KSeF ensure compliance and offer traceability.
Table 2: When Foreign Entities Must Use KSeF
| Scenario | Obligation to Use KSeF |
| Foreign company with Polish VAT registration having fixed establishment in Poland | Yes |
| Issuing invoices for supply of goods in Poland | Yes |
| Receiving invoices issued in KSeF format | Yes |
| Not having fixed establishment in Poland | No |
Common Issues When Issuing Foreign Currency Invoices
Some common issues encountered by businesses include:
– Incorrect exchange rates being applied.
– VAT not being shown in PLN, which invalidates the invoice for VAT purposes.
– Failure to use the KSeF when required.
– Not including all required data for invoices issued in a foreign currency.
Best Practices
To ensure compliance with Polish VAT regulations:
1. Always refer to the National Bank of Poland exchange rate table for the correct rate.
2. Confirm whether your company is obliged to issue invoices via KSeF.
3. Store all invoices in a structured electronic format.
4. Clearly express VAT in PLN on every invoice issued in a foreign currency.
Related Content
– [VAT Compliance for Foreign Businesses in Poland](https://polishtax.com/vat-compliance-poland/)
– [KSeF Obligations for EU and Non-EU Entities](https://polishtax.com/ksef-obligations/)
By following the above guidance, foreign businesses operating in Poland can ensure they issue VAT-compliant invoices in foreign currencies, avoid penalties, and streamline their reporting in the national e-invoicing system.
Summary
To ensure compliance with Polish VAT regulations, particularly in the context of issuing invoices in foreign currencies and the mandatory National e-Invoicing System (KSeF), foreign businesses should take the following practical steps and precautions:
- Correct VAT conversion to PLN: Even if the invoice is issued in a foreign currency, the VAT amount must be expressed and reported in Polish zloty (PLN). Failure to report VAT in PLN invalidates the invoice for VAT purposes.
- Using the correct exchange rates: When converting VAT to PLN, always use the average exchange rate for the relevant foreign currency announced by the National Bank of Poland (NBP). This rate should be from the last business day preceding the invoice issuance date. Always refer to the NBP exchange rate table to verify the correct rate.
- Ensuring compliance with KSeF:
- From February 2026, the use of KSeF is mandatory for all VAT payers in Poland, including foreign companies registered for VAT purposes in Poland. ◦ All invoices issued in foreign currencies must be submitted through the KSeF system if the seller is subject to this system.
- Confirm whether the company is required to issue invoices through the KSeF system. This obligation applies to foreign companies with a Polish VAT number, issuing invoices for the supply of goods in Poland, and receiving invoices in the KSeF format. Companies not registered for VAT in Poland are not required to use the KSeF system.
- Storing invoices electronically: All invoices must be stored electronically in accordance with the KSeF system.
- Completing all required data: Ensure that all required data is included on foreign currency invoices.
Following these guidelines will help avoid common problems, such as using incorrect exchange rates, failing to report VAT in PLN, or failing to use the KSeF system when required.