In this article, you will learn:
• What is VAT self-billing?
• What is the legal basis for self-billing?
• What requirements must be met for self-billing?
• What you need to know about self-billing in the KSeF
• What are the benefits and risks associated with self-billing?
What is VAT Self-Billing?
VAT self-billing is an arrangement where the customer issues invoices on behalf of the supplier. While unusual at first glance, this mechanism is fully recognized under EU VAT law, provided there is a formal agreement between the parties.
It is particularly common in sectors with frequent, repetitive transactions, where suppliers deliver high volumes of goods or services and the buyer holds stronger administrative capacity.
Legal Basis
Pursuant to Article 224 of Council Directive 2006/112/EC of 28.11.2006 on the common system of value added tax, hereinafter referred to as the VAT Directive, invoices may be issued by a purchaser or recipient of services in respect of supplies of goods or services to them by a taxable person, where there is a prior agreement between the two parties and provided that, that there is a specific procedure for approving individual invoices by a taxpayer supplying goods or services. A Member State may require such invoices to be issued in the name and for the benefit of the taxable person.
Similar provisions can be found in Article 106d of the Polish VAT Act.
Legal Requirements
Self-billing can only be applied if:
- Both parties sign a written agreement prior to implementation.
- The supplier accepts invoices issued on their behalf.
- Each invoice clearly states “self-billing” and complies with VAT regulations.
- Businesses maintain internal controls to ensure invoices are correct and VAT is properly accounted for.
- Some EU countries require notification to tax authorities or periodic renewal of the agreement.
Data to be included in the invoice issued by the buyer of goods and services
The provisions of Article 106e of the Tax Act apply to all invoices, also issued by buyers of goods and services.
Thus, pursuant to Article 106e(1)(1-15) of the Tax Act, the invoice should include:
- date of issue,
- a successive number assigned within one or more series, which unambiguously identifies the invoice,
- names and surnames or names of the taxpayer and the buyer of goods or services and their addresses,
- the number by which the taxable person is identified for tax purposes, subject to point 24(a),
- the number by which the purchaser of goods or services is identified for tax or value added tax purposes under which he received the goods or services, subject to point 24(b),
- the date of delivery or completion of the delivery of goods or performance of services or the date of receipt of payment referred to in Article 106b(1)(4) of the Tax Act, if such a date is specified and differs from the date of issue of the invoice,
- the name (type) of the good or service,
- the measure and quantity (number) of goods delivered or the scope of services provided,
- unit price of goods or services excluding the amount of tax (net unit price),
- the amount of any discounts or price reductions, including in the form of a rebate for early payment, as long as they have not been included in the net unit price,
- the value of goods or services provided, covered by the transaction, excluding the amount of tax (net sales value),
- tax rate,
- the sum of the net sales value, divided into sales covered by individual tax rates and sales exempt from tax,
- the amount of tax on the sum of the value of net sales, divided into amounts related to individual tax rates,
- the total amount of receivables.
In addition, pursuant to Article 106e(1)(17) of the Polish VAT Act, invoices issued by buyers of goods and services should also contain the word “self-invoicing”.
Benefits vs. Risks
Below is a comparison of potential advantages and challenges when using VAT self-billing:
| Aspect | Benefits | Risks / Challenges |
| Administrative | Reduces paperwork for suppliers, efficient for bulk transactions | Incorrect invoice details may lead to disputes or corrections |
| VAT Compliance | Ensures invoices match purchase records, reducing mismatches | Errors in VAT rates or missing elements can result in tax penalties |
| Cash Flow | Streamlined process may speed up invoicing and payments | Customers may delay issuing invoices, affecting supplier’s payment timeline |
| Transparency | Clear, consistent documentation builds trust in regular supply chains | Requires strong internal controls and monitoring |
| Industry Use | Works well in agriculture, transport, and online platforms | Not all suppliers are willing to delegate invoicing authority to buyers |
Practical Use Cases
- Agriculture: buyers purchasing raw goods from many small farmers.
- Logistics: frequent fuel, freight, or toll transactions managed by large customers.
- Marketplaces: online platforms issuing invoices on behalf of sellers.
Self-Billing and KSeF
KSeF, i.e. the National e-Invoicing System, is not limited in scope to the method of issuing invoices by taxpayers. The KSeF environment, which consists of legal, accounting, accounting and technological aspects, has a very large impact on the business processes currently used and implemented by taxpayers.
After the entry into force of the KSeF, self-invoicing will still be possible, but the scope of formal requirements necessary for proceedings within this institution will be significantly broadened – it will be necessary to grant appropriate rights to the entity that is the buyer of goods or services from the taxpayer in a given relationship.
Despite the fact that the provisions introducing the KSeF do not interfere with the wording of Article 106d(1) of the Tax Act, as of 1.02.2026 (and respectively 1.04.2026 for smaller taxpayers), the mere signing of a self-invoicing agreement with an indication of the procedures for approving invoices in its content will not be sufficient to be able to issue invoices in the name and for the benefit of one’s contractor in KSeF in practice. A prerequisite will be to have the rights granted by the other party to the transaction.
One of the rights available in KSeF is the possibility to grant the entity being the buyer in a given transaction the right to issue invoices in the name and for the benefit of the supplier. This possibility is clearly the implementation of the self-invoicing procedure.
Authorizations are assigned to specific natural persons (identification by NIP, PESEL or qualified signature certificate).
Self-invoices must contain the appropriate annotation in the P_17 field and the customer’s data in the Subject2 element.
An additional issue related to self-invoicing, which needs to be clarified after the entry into force of the mandatory KSeF, is the invoice approval procedure. This procedure should take into account the moment of approval of the document, before it is sent to the KSeF or after it. However, taking into account the statutory provisions according to which a document is considered an invoice after it has been sent to KSeF, it should be considered that acceptance should, in principle, take place after sending the invoice to KSeF, e.g. in the form of tacit consent.
Therefore, in order to continue self-invoicing after 1 February 2026, companies should annex the existing agreement by adding provisions regarding the issuance of invoices in KSeF and defining the procedure for approving invoices issued using KSeF. At the same time, it is recommended to add provisions concerning the granting of appropriate permissions.
To sum up, Self-invoicing is one of those issues that will not be subject to radical legal changes after the mandatory KSeF enters into force. However, it is self-invoicing, due to the change in the technological environment, that will result in taxpayers having to prepare procedurally and technically for de facto daily monitoring of the self-invoicing rights granted to them on behalf of and for the benefit of their contractors.
Conclusion
VAT self-billing can significantly improve efficiency in repetitive, high-volume transactions. However, it requires:
- A clear legal agreement between parties.
- Robust compliance procedures.
- Regular monitoring of VAT obligations.
Before implementing self-billing, businesses should review EU and local VAT legislation and consult with a professional tax advisor.
Our team of consultants and accountants at Intertax is ready to help your company meet the legal requirements for accurate VAT reporting. Contact us and we will provide professional assistance.