KSeF for foreign companies: are you in scope?

If your business is registered outside Poland but you sell there, the first question about KSeF is simply: do I have to use it? The answer usually turns on one concept — a fixed establishment.

This is a high-level orientation, not tax advice. Fixed-establishment determinations are fact-specific — confirm your position with a Polish tax advisor.

The deciding factor: fixed establishment (FE)

• No fixed establishment in Poland — a foreign company merely VAT-registered

in Poland (e.g. for distance sales or a warehouse) is generally not obliged to issue through KSeF for its Polish transactions.

• With a fixed establishment in Poland that participates in the supply — you

may fall in scope for issuing via KSeF, like a domestic business.

So "I have a Polish VAT number" does not by itself put you in scope; "I have a Polish establishment that makes the sale" often does.

Receiving is a separate question

Even if you don't issue through KSeF, your Polish B2B customers or suppliers may operate within it. Understand how you'll obtain invoices addressed to your Polish VAT number, and how corrections reach you.

Cross-border sales aren't domestic KSeF

Selling from another EU country into Poland, or from Poland abroad, is cross-border — handled by EU rules and, increasingly, Peppol/ EN 16931, plus VAT mechanisms like OSS and the reverse charge. KSeF is Poland's domestic system; it isn't the channel for your cross-border invoices.

A quick decision guide

Do you have a fixed establishment in Poland that makes the supply?
  → Yes: likely in scope to issue via KSeF — confirm with an advisor
  → No, only VAT-registered: generally not obliged to issue via KSeF
Selling cross-border to/from Poland?
  → Use EU e-invoicing (Peppol/EN 16931) + the right VAT treatment
Do Polish counterparties operate in KSeF?
  → Plan how you receive/reconcile their invoices

What to do next

1. Get a written view on your fixed-establishment status.
2. Map which of your Polish flows are domestic vs cross-border.
3. For domestic-in-scope flows, plan KSeF issuance (direct or via a provider).
4. For cross-border flows, make sure your EU e-invoicing is in order.

Where Eurobillr fits

Eurobillr is built for the cross-border EU side — Peppol/EN 16931 send and receive, VAT handling, multi-currency — which is exactly what a foreign company trading with Poland needs for its cross-border invoices. Domestic KSeF issuance (when you're in scope) is Poland's national system; you'd use KSeF directly or a KSeF provider for that. If your Polish footprint needs both, tell us what you're running into.

Related: invoicing clients in another EU country.