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[Poland Specific] KSeF E-Invoicing

Understanding KSeF E-Invoicing in Poland

What Is KSeF?

The National e-Invoicing System (KSeF) is Poland's official electronic invoicing platform used for issuing, receiving, storing, and verifying invoices in a standardized electronic format.

In February 2026, Poland introduced mandatory KSeF e-invoicing for business-to-business (B2B) transactions. As part of this change, invoices for purchases and bonus payments are submitted electronically to KSeF, where they can be accessed and downloaded. To maintain a consistent invoicing process, Amway also decided to issue invoices for Customers and Member+ members through KSeF.

Key benefits of KSeF include:

  • Centralized access to invoices.
  • Faster invoice verification.
  • Standardized invoice formats.
  • Secure storage of official invoice records.

Granting Permission for Invoice Issuance in KSeF

To enable Amway to issue invoices through KSeF on an ABO's behalf, the ABO must grant the required authorization during Legal Entity registration (when changing status from Member+ to ABO).

If this authorization is not granted:

  • Amway cannot issue invoices on behalf of the ABO.
  • The status change cannot be completed.
  • The Legal Entity registration cannot be finalized.

Accessing Purchase Invoices in KSeF

How ABOs Can Access Their Invoices

ABOs can access invoices in the following ways:

Access Through KSeF

  • Log in to KSeF using the company's Tax Identification Number (NIP).
  • View all invoices issued to the company.

Access Through Invoice Visualization

  • Amway sends a PDF invoice visualization by email.
  • The PDF contains a QR code.
  • Scanning the QR code redirects the ABO to the original invoice stored in KSeF.

When Invoices Become Available in KSeF

Invoices are generally available on the same day they are issued.

  • Invoices are issued on the shipping date.
  • They are submitted to KSeF immediately after issuance.
  • Minor delays may occur if KSeF is experiencing unusually high traffic.

Receiving Invoices Without KSeF Registration

Amway is required to issue invoices through KSeF regardless of whether the ABO is registered in the KSeF portal.

What the ABO Receives

  • A PDF invoice visualization by email.
  • The PDF serves as a visualization only and is not the official invoice.
  • A QR code is included that links to the original invoice in KSeF.

Access to the Original Invoice

The original invoice remains available in KSeF regardless of whether the ABO has previously logged in or registered.


Invoices for Customers and Member+ Members

How Member+ Members Access Invoices

Member+ members do not have a Tax Identification Number (NIP) and therefore receive:

  • A PDF invoice visualization via email.
  • A QR code that allows them to access and verify the original invoice in KSeF.

Why Customers and Member+ Members Receive KSeF Invoices

Although KSeF was introduced as a B2B requirement, Polish regulations allow companies to use KSeF for B2C invoices as well.

Amway decided to implement KSeF for both:

  • Business customers (B2B)
  • Private customers (B2C)

This creates a single, standardized invoicing process regardless of customer type.


Personal Data on Customer Invoices

Invoices issued to private individuals do not contain:

  • PESEL numbers
  • NIP numbers

As a result, these invoices do not provide sufficient information for tax authorities to directly identify private customers.


How Member+ Discounts Appear on Invoices

Currently:

  • Invoice visualizations show only the final purchase price.
  • Member+ discount details are not displayed separately.

This invoice design may change in the future.


Invoice Delivery Email Address

Invoices for Customers and Member+ members are sent through SOVOS from:

delta.notifications@sovos.com


Incorrect Invoice Visualization

If the invoice visualization appears incorrect:

  1. Scan the QR code included on the invoice.
  2. Open the original invoice directly in KSeF.
  3. Verify the invoice details using the official KSeF document.

The QR code always links to the correct invoice stored in KSeF.


Determining Business and Private Purchases

How ABOs Classify Purchases

The introduction of KSeF does not change the ABO's responsibilities.

While Amway issues the invoices, the ABO remains responsible for determining whether a purchase is:

  • Related to business activities, or
  • Intended for private use.

ABOs should consult their accountant to determine how business and personal expenses should be recorded and reported.


Understanding Invoice Data

Why Payment Dates May Differ

Amway uses third-party payment providers such as:

  • BLIK
  • PayPal
  • Other payment intermediaries

Payment is considered received when the payment provider confirms the transaction to Amway, which may occur later than the date the customer initiated the payment.


Why the Invoice Date Matches the Shipping Date

For tax purposes, the order placement date is not relevant.

Amway uses the shipping date as both:

  • Invoice date
  • Order date

This is because the tax obligation arises when:

  • Goods are delivered,
  • Services are provided, or
  • Payment is received.

For payments made through intermediaries, payment is considered received when Amway obtains confirmation from the payment provider.


Why SKU Numbers Are Not Included on KSeF Invoices

SKU numbers are internal Amway product identifiers.

Because SKU information is not legally required on invoices:

  • SKU numbers are not displayed on KSeF invoices.
  • There are currently no plans to add them.

Group Order Invoices

Are Total Group Amounts Displayed on KSeF Invoices?

No.

KSeF invoices display only the amount assigned to the individual ABO.

However, the main order summary continues to show:

  • The individual invoice amount.
  • The total amount for the group order.

Why Does a Group Order Invoice Show "Total Amount Due" (Kwota Należności Ogółem)?

This information is displayed correctly.

The invoice reflects the amount actually paid by a specific ABO. As a result:

  • Amway's accounting records show the full amount received from that ABO.
  • The amount shown matches the amount visible on the ABO's bank statement.

VAT and Invoice Types

How Invoices Are Issued for Non-VAT Payers

Amway is legally required to issue VAT invoices for product sales.

As a result:

  • All product invoices include VAT.
  • Invoice format remains the same regardless of the ABO's VAT status.

How Bonus Invoices Are Issued

For ABOs who benefit from VAT exemption:

  • Bonus invoices are issued without VAT.

Which Period Does Bonus Income Relate To?

Bonus income relates to the period during which the service was performed, not the date on which the invoice was issued.

For example:

  • If the invoice specifies a service completion period of 01.01.2026 to 31.01.2026, the income legally belongs to January 2026.

The service period is shown in the field:

"Data dokonania lub zakończenia dostawy towarów lub wykonania usługi" (Date of completion of delivery or service).


SOVOS Invoice Processing

How SOVOS Supports Invoice Delivery

Invoices are processed and uploaded through SOVOS.

SOVOS acts solely as a processor on behalf of Amway and is not a joint data controller.

Its responsibilities include:

  • Processing invoice data.
  • Uploading invoices.
  • Sending invoice visualizations to customers.

These activities are carried out under Amway's legal basis for processing personal data.


Legal Basis for Processing Personal Data

Invoice processing is performed under:

GDPR Article 6(1)(c)

Processing required to comply with legal obligations, including:

  • VAT regulations.
  • KSeF requirements.

GDPR Article 6(1)(b)

Processing required for the performance of a contract, including:

  • Issuing invoices.
  • Delivering invoice copies and visualizations to customers.

All processing activities performed by SOVOS are carried out on behalf of Amway under these legal bases.

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