What is self-billing?

Self-billing is an arrangement in which the buyer, rather than the supplier, generates the invoice for goods or services received. The buyer prepares and issues the document in the supplier’s name, and both parties treat it as the supplier’s invoice for VAT purposes.

The practice is common in business-to-business relationships with regular, repetitive transactions, or where the buyer holds the data needed to calculate what is owed. A streaming platform that pays creators based on views, for example, already knows each creator’s earnings, so it is better placed to raise the invoice than the creator is. Used well, self-billing streamlines invoicing and speeds up payment. Used without the right controls, it creates VAT risk for both sides — which is why EU and national law set specific conditions.

What are the EU legal requirements for self-billing?

Under Article 224 of Council Directive 2006/112/EC, self-billing is permitted only where two conditions are met: there is a prior agreement between the buyer and the supplier, and a procedure exists for the supplier to accept each invoice. Both parties are normally expected to be VAT-registered.

The first requirement is a written agreement setting out how the arrangement will work. It should record each party’s responsibilities, the process for generating and issuing self-billed invoices, the invoicing frequency, the payment terms, and any other relevant details. The agreement is what gives the buyer authority to invoice in the supplier’s name.

The second requirement is an acceptance procedure. Each self-billed invoice must be accepted by the taxable person supplying the goods or services, so the supplier keeps oversight of documents issued on its behalf. Acceptance can be explicit, or — where the agreement allows — implied: many Member States, including Poland, permit tacit acceptance, under which silence within an agreed window counts as approval.

What information must a self-billed invoice contain?

A self-billed invoice must display the reference “self-billing” and carry every mandatory particular listed in Article 226 of the VAT Directive. The label is what distinguishes it from an ordinary invoice; the remaining details are the same as for any compliant VAT invoice.

In practice, a compliant self-billed invoice includes the names and addresses of both the buyer and the supplier; the invoice date, together with the date of supply where it differs; a unique sequential invoice number; and a clear description of the goods or services provided. It must also state the quantity and price, the taxable amount per rate or exemption, and the unit price excluding VAT, along with any discounts or rebates not already reflected in that unit price. Finally, it must show the VAT rate applied and the VAT amount payable.

Who is responsible for VAT in a self-billing arrangement?

The buyer prepares the invoice and must apply the correct VAT treatment, while the supplier remains the taxable person responsible for the VAT due on the supply. Responsibility is therefore shared, and both sides have a duty to check.

Because the buyer draws up the document, it is the buyer’s job to apply the right VAT rate and treatment to each transaction. The supplier, however, does not hand over its obligations by entering a self-billing arrangement: it must verify that every self-billed invoice it receives accurately reflects the transaction and is consistent with its own VAT reporting. If an invoice is wrong, both parties are exposed, so the acceptance procedure is the practical safeguard against errors entering the VAT records.

What records must businesses keep?

Both the buyer and the supplier must keep accurate records of self-billed invoices and the underlying transactions to demonstrate compliance. In Poland, invoices must be retained for at least five years.

If a tax audit or investigation follows, a business must be able to produce evidence supporting the accuracy and legitimacy of the invoices it has issued or received. Good record-keeping is not just a formality; it is the difference between resolving a query quickly and facing an assessment.

What happens if you do not comply?

Failure to meet self-billing requirements can lead to penalties, fines, or other sanctions from the tax authorities — and, in Poland under KSeF, the inability to issue a legally valid invoice at all.

The consequences range from financial penalties to disallowed VAT recovery and disrupted cash flow. Where mandatory e-invoicing applies, an invoice that is not correctly issued through the national system simply has no legal force, which can stall payment entirely. Understanding the rules before an arrangement begins is far cheaper than remediating problems after an audit.

What are the self-billing rules in Poland?

Poland applies the EU framework through Article 106d of its VAT Act, with the same two core conditions — a written agreement and an acceptance procedure — plus national specifics.

The written agreement must, as in the wider EU, define each party’s responsibilities and the process for issuing self-billed invoices, and in particular set out the procedure by which the supplier accepts each invoice. Polish law expressly allows that procedure to be based on tacit acceptance: if the supplier raises no objection within the timeframe agreed, the invoice is treated as accepted.

On invoice content, Polish self-billed invoices must show the reference “self-billing” in Polish, samofakturowanie. Alongside the standard EU particulars, they must include both parties’ full names and addresses and their tax identification numbers (NIP), the invoice and supply dates, a unique number, a description of the goods or services, the quantity and price, the taxable amount per rate or exemption, the net unit price with any discounts, the VAT rate, and the VAT amount payable.

On VAT, records and penalties, the Polish position mirrors the EU rules: the buyer applies the correct VAT treatment as the party preparing the invoice, the supplier verifies it, both retain records for at least five years, and non-compliance can trigger penalties or sanctions.

How does KSeF affect self-billing in Poland?

From 2026, most invoices in Poland — including self-billed ones — must be issued as structured XML through KSeF, the National e-Invoice System. KSeF uses a clearance model: an invoice has no legal force until the system has validated and accepted it.

The mandate is phased by taxpayer size. Large taxpayers, with 2024 sales above PLN 200 million, have had to issue invoices through KSeF since 1 February 2026. Most other VAT-registered businesses follow from 1 April 2026, and the smallest micro-enterprises (monthly sales up to PLN 10,000) from 1 January 2027. Invoices use the FA(3) XML schema, and businesses must keep records for at least five years.

For self-billing specifically, the buyer must confirm that an invoice prepared on the supplier’s behalf is correct before it enters legal circulation — that is, before the XML file is sent to KSeF. Once an invoice is cleared, it cannot simply be edited, so the acceptance step has to happen upstream, inside the buyer’s and supplier’s own processes.