KSeF offline mode should be treated as a controlled emergency process. The company needs a switch-over decision, emergency numbering, invoice archive, responsibility matrix and evidence that invoices were submitted after the system or integration was restored.
What does KSeF offline mode mean?
KSeF offline mode means that invoices are issued outside the normal system communication path and later submitted to KSeF. It may result from a KSeF outage, ERP failure, integration error or connectivity issue. The accounting risk is not only technical availability. It is completeness, authorisation and audit trail.
What should the emergency procedure include?
- who declares offline mode and who approves it,
- how invoices are numbered and protected against duplication,
- how invoices are archived and matched to later KSeF submissions,
- who monitors unresolved exceptions,
- how management receives a completeness report after the outage.
Internal controls and segregation of duties
The same person should not be able to issue emergency invoices, change master data, approve exceptions and close the log without review. Segregation of duties remains relevant even during system failure. Emergency access should be time-limited, logged and reviewed by finance management.
Archiving and evidence
The company should retain invoices issued in emergency mode, system messages, decision logs, submission confirmations, exception lists and evidence of reconciliation to sales ledgers. This is important for VAT compliance, KSeF governance and audit evidence.
What should the CFO monitor?
The CFO should receive a concise dashboard: number of invoices issued offline, value, responsible owner, submission status, unresolved exceptions and ageing. If the dashboard does not exist, the company may not know whether all emergency invoices reached KSeF.
Frequently asked questions
Need a KSeF emergency procedure?
JMFC can help finance teams document KSeF offline controls, responsibilities and audit trail before the first real outage.