Self-billing
an invoice issued by the buyer
Self-billing is a procedure in which the buyer issues the invoice in the name of and on behalf of the seller. RAFSOFT software — Faktura VAT 2026 for Windows and Mobilna Faktura online — supports self-billing in line with the Polish VAT Act and the requirements of KSeF (field P_17).
What is self-billing?
In a standard transaction the invoice is issued by the seller. Under self-billing the roles are reversed: the invoice is prepared by the buyer, yet it is still an invoice documenting a sale made by the seller. The procedure is governed by Article 106d of the Polish VAT Act.
Why would the buyer issue the invoice?
In many cooperation models it is the buyer — not the seller — who holds the complete and most up-to-date transaction data: quantities, prices, delivery dates or accrued commissions. Self-billing lets them issue the document straight away, without waiting for the supplier's invoice, which speeds up settlements and removes data re-entry errors.
A self-billed invoice is a fully valid VAT document. The seller remains the taxable person for that sale — the only thing that changes is who technically prepares and (with KSeF) sends the invoice.
In brief
- The invoice is issued by the buyer, not the seller
- Basis: Article 106d of the Polish VAT Act
- Requires a prior agreement between the parties
- The agreement sets out the invoice approval procedure
- The invoice carries the word „samofakturowanie”
- In KSeF: a flag in field P_17
- Output VAT is accounted for by the seller
Who uses self-billing most often?
Self-billing works well in ongoing, repeatable cooperation where it is the buying party that keeps the record of transactions.
Retail chains and distributors
They settle with many suppliers based on their own goods-receipt systems, issuing invoices for those suppliers in line with the agreements in place.
Buyers of agricultural produce and raw materials
Companies buying from many small suppliers (farmers, scrap and recycling collection points) prepare invoices based on the quantities and prices recorded at the moment of receipt.
Commission and intermediary settlements
Platforms and intermediaries that charge commission to their partners can issue invoices on behalf of those partners based on settlement data.
Ongoing, repeatable cooperation
Wherever transactions recur regularly and the buyer knows the exact parameters of every delivery, self-billing shortens the document flow.
Self-billing conditions — what to keep in mind
For self-billing to comply with the regulations, specific formal conditions must be met.
The seller and the buyer conclude a prior agreement authorising the buyer to issue invoices in the name of and on behalf of the seller. The agreement should indicate which transactions it covers.
The agreement must define how the seller approves individual invoices issued by the buyer (for example tacit acceptance within a set deadline or active confirmation).
An invoice issued under this procedure should contain the word „samofakturowanie”, so that it clearly states that the document was prepared by the buyer on behalf of the seller.
The invoice must carry the correct details of the seller (as the party making the sale) and of the buyer. RAFSOFT software keeps these details separate in line with the invoice structure.
Please note: this page is for information only and does not constitute tax advice. It is worth discussing the detailed self-billing rules for your situation with an accountant or a tax adviser.
Self-billing and KSeF — field P_17
In the National e-Invoicing System (KSeF) self-billing is indicated by a flag in field P_17 of the FA logical structure. The flag tells the system that the invoice was issued by the buyer on behalf of the seller.
RAFSOFT software sets field P_17 automatically and builds the invoice structure so that KSeF accepts the document and assigns it to the correct parties. As a result, self-billing works fully electronically — with no manual editing of the XML structure.
See also how the software handles structured KSeF invoices and the full table of invoice types sent to KSeF 2.0.
Self-billing in KSeF
Supported in both RAFSOFT products:
- Faktura VAT 2026 (Windows)
- Mobilna Faktura (online)
- Automatic field P_17
- Sending to KSeF with UPO
Frequently asked questions about self-billing
What is self-billing?
Self-billing is a procedure in which the buyer of goods or services issues the invoice in the name of and on behalf of the seller. It is based on Article 106d of the Polish VAT Act. It requires a prior agreement between the parties and a defined procedure for the seller to approve invoices.
When is self-billing used?
Most often in ongoing, repeatable cooperation where the buyer holds the complete transaction data — retail chains settling with suppliers, buyers of agricultural produce and recyclable materials, intermediary platforms and commission settlements.
What conditions must be met to use self-billing?
A prior agreement is required, authorising the buyer to issue invoices on behalf of the seller and setting out the invoice approval procedure. The invoice should contain the word „samofakturowanie”. The seller remains the taxable person for the sale.
How does self-billing work in KSeF?
In KSeF, self-billing is marked in field P_17 of the FA structure. Faktura VAT 2026 and Mobilna Faktura set this flag and send the invoice to KSeF in a valid structure.
Who accounts for VAT under self-billing?
Output VAT on the sale is accounted for by the seller — it is their sale, even if the invoice was technically issued by the buyer. The buyer deducts input VAT under the general rules.
Find out more
Invoice — including under the self-billing procedure
Issue an invoice on behalf of the seller, mark it correctly and send it to KSeF with field P_17 set — in Mobilna Faktura online or in Faktura VAT 2026 for Windows.