QR code as a way to verify structured invoice

The requirement to mark a visualized structured invoice, e.g. either in PDF format or to paper, with a verification code is another of the new obligations to be imposed on VAT taxpayers in connection with the planned introduction of the mandatory KSeF. Marking the visualization of an invoice with such a code will make it possible, in particular, to verify that a given invoice was issued in KSeF and that the data on it is correct.

What is a verification code?

According to the draft regulation of the Minister of Finance on the use of the National e-Invoice System (KSeF), the verification code is understood to be a unique string of characters presented in the form of a two-dimensional square QR graphic code compliant with ISO/IEC 18004:2015. The elements of the verification code are to be defined by the aforementioned regulation.

When will there be a QR code on a structured invoice?

The obligation to mark a structured invoice with a verification code will occur in two cases, i.e.: making this invoice available in ways other than using KSeF, and using it outside KSeF.

It should be noted that in certain situations, the provision of a structured invoice outside KSeF will be an obligation of the taxpayer – such as the case when:

  • the place of supply will be a country other than Poland, or
  • the purchaser will be an entity that does not have its registered office or permanent place of business in Poland, or
  • the purchaser will be an entity without a registered place of business in Poland which has a fixed place of business in Poland, when this fixed place of business will not participate in the supply of goods or services for which the invoice is issued.

In practice, the obligation to mark the invoice with a QR code will apply in particular to so-called foreign transactions, i.e. WDT, export of goods, export of services or supplies taxable outside Poland. What will be irrelevant to the obligation to mark an invoice with a QR code, however, is the fact that the buyer has not used the verification code.

While the obligation to mark invoices with a QR code does not apply to cases where invoices are used for internal taxpayer purposes, it may nevertheless make sense to use only invoices that contain this mark to ensure the security of the company’s document flow.

Access to an invoice without authentication in KSeF

Marking structured invoices with a QR code will allow buyers to access these invoices in KSeF (after providing additional data, i.e., the buyer’s VAT ID and invoice number) without authentication.