KSeF – How to Correctly Calculate the PLN 200 Million Gross Sales Threshold
With the upcoming introduction of the National e-Invoicing System (KSeF), determining whether a company exceeded the PLN 200 million total gross sales threshold in 2024 is of key importance. Exceeding this limit means an earlier obligation to use KSeF for sales purposes – as of 1 February 2026, instead of 1 April 2026.
How to Calculate the Sales Threshold
Current regulations do not explicitly indicate the data source that should be used to determine the PLN 200 million (gross) threshold. In practice, the calculation should be based on the definition of “sales” under the VAT Act.
The following transactions should be included in the calculation:
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taxable supplies of goods and services within Poland,
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exports of goods,
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intra-Community supplies of goods (ICS).
The following should not be included:
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purchases for which VAT is settled by the buyer (e.g. intra-Community acquisitions of goods, import of services),
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sales where the place of supply is located outside Poland.
Which Data Source to Use
The most reliable basis for determining the threshold is the SAF-T filings for the entire year 2024. These reports most accurately reflect the total gross sales value as defined under VAT regulations. Financial statements may include amounts that do not align with the statutory definition of sales.
Why It Matters
Correctly determining whether the PLN 200 million threshold has been exceeded is a crucial step in the KSeF implementation process. Misinterpretation of the rules or using inappropriate data sources could lead to compliance issues. To mitigate risks, companies should verify their sales data early and seek expert advice on proper calculation methods.