The date of the obligatory start of the KSeF is approaching inexorably. It is worth considering what impact this will have on cash registers.
Sales recorded at the cash register are recorded in SAF_VAT – as before – collectively on the basis of a cash register report, as an internal document marked RO (§ 10 section 5 of the Decree of the Minister of Finance on the detailed scope of data contained in tax returns and in VAT records). It is a record item in the SAF-T and not an invoice.
Such a report is not a VAT invoice, so by definition it is not a document that can be issued/received in KSeF.
From the point of view of KSeF, the following are important:
- structured invoices (XML) with a KSeF number, which will then be reported in the new SAF-T structure – KSeF numbers for sales and purchase invoices will have to be shown in SAF-T invoices;
- invoices generated from cash registers – but only if the regulations include them in the mandatory KSeF.
Until 31 December 2026, invoices generated using cash registers (including receipts with NIP treated as simplified invoices) are excluded from the obligation to issue in the KSeF. This means that:
- it is still possible to issue invoices from the cash register outside the KSeF,
- sales with a registered cash register are still recognised collectively in JPK_V7 as a RO document,
- reports from the cash register are not “passed” through the KSeF – the system does not handle them at all, because reports are not invoices.
Only after the end of the transitional period (from 2027) is the possibility of issuing invoices from cash registers and recognizing receipts from the NIP as simplified invoices is to be abolished. Even then, however, the cash register report itself will still remain a record document (and not an invoice), so it will not be sent to KSeF.
Important: The cash report should also be marked with the “DI” mark in the SAF_VAT.
