Tax risk / CFO

KSeF and tax audits — what the tax authority sees and how to prepare

KSeF is not just a change in invoice format — it is a fundamental change in the tax authority's access to transaction data. Every VAT invoice is visible to the Ministry of Finance in near-real time. What does this mean for audit risk?

29.04.2026 7 min read Tax risk / Tax inspection
01
KAS sees every invoice from a counterparty and can automatically compare it against your records — before you file VAT.
02
A discrepancy between a KSeF invoice and a JPK_VAT or JPK_CIT entry is an automatic trigger for the KAS analytics system.
03
Related-party transactions are now fully visible by tax ID — transfer pricing is under greater scrutiny.
CFO summary (30 seconds):
KSeF gives tax authorities access to detailed invoice data in near-real time. KAS analytical systems can automatically compare sales invoices at one taxpayer with cost invoices at another, detect discrepancies against JPK_VAT and JPK_CIT, and identify related-party transactions. For CFOs this means one thing: record consistency is no longer optional. Every invoice is now directly accessible to the authority — with date, amount and counterparty.

Does this apply to your company

This article applies to you if you meet at least one condition:

  • You are an active VAT taxpayer — from 1 February or 1 April 2026 you issue invoices through KSeF
  • You conduct related-party transactions — KSeF identifies them automatically by tax ID
  • You have historical discrepancies between VAT records and CIT records
  • You apply special cost recognition rules (limited-deductibility costs, non-deductible costs, intragroup intangible services)
  • Your sector is typically targeted by KAS inspections (construction, IT, high-value goods trading, intragroup intangible services)

What the authority sees — 4 data areas

Data available in KSeFWhat KAS can automatically check
Every VAT invoice with issuer and recipient tax ID, date, amount, VAT rate Comparing the sales invoice at the supplier with the cost invoice at the buyer — detecting unreported invoices
Invoice date and KSeF number assignment date Verifying timely VAT reporting — whether the invoice was included in JPK_V7 in the correct period
Tax ID of all counterparties on every transaction Automatic identification of ownership links and related-party transactions
Invoice values per counterparty per period Detecting anomalies: sudden transaction volume changes, unknown counterparties, mutual invoice corrections

KSeF as a KAS analytics tool — how it works

Before KSeF the tax authority had data from JPK_VAT — a list of invoices in a file submitted after each month end. These were retrospective data, selectively analysed by the authorities.

KSeF changes this fundamentally. Every invoice is available to the Ministry of Finance at the moment of issuance — before the VAT return is filed. This means the KAS analytics system can:

  • Compare company A's sales invoices with company B's cost invoices before both file JPK_V7
  • Identify invoices issued in KSeF that were not included in the taxpayer's JPK_VAT
  • Detect "duplicate" or "cancelled" invoices outside KSeF
  • Build taxpayer transaction profiles with data going back several years
Auditor's perspective: In an audit we always verify completeness of revenue and cost recognition. KSeF means that same verification is now available to the tax authority — automatically and in real time. If your records are inconsistent with KSeF data, the authority will see it faster than your auditor.

How to prepare your company — auditor's perspective

Step 1 — Reconcile historical JPK_VAT records against KSeF data

Before KSeF goes live it is worth conducting an internal review of the last 3 years: are all cost invoices you claimed as input VAT present at the counterparty? Discrepancies discovered now can be explained or corrected. Discrepancies discovered by the tax authority are grounds for initiating an audit.

Step 2 — Document cost classification rules

Under JPK_CIT every entry must have a deductible/non-deductible marker. The tax classification decision must be documented and approved — not made ad hoc by the bookkeeper. The tax advisor or CFO must approve the rules for each cost category.

Step 3 — Review transfer pricing documentation

KSeF automatically identifies related-party transactions. If your transfer pricing documentation is out of date or incomplete — KSeF will give KAS the full transaction volume picture, increasing the probability of a transfer pricing audit.

Step 4 — Verify credit notes

Credit notes (upward and downward adjustments) must be included in VAT records in the correct period. In KSeF every credit note has its own number and date — the KAS system sees credit notes and compares them against both parties' returns.

High-risk areas after KSeF implementation

  • Unbooked or delayed cost invoices — the counterparty issued the invoice in KSeF but you did not book it in the same period. The authority sees the gap.
  • Invoices "outside KSeF" — if the company issued any invoices outside the mandatory system (e.g. in offline mode not in compliance with the rules), KAS will detect this by comparing data.
  • VAT rate discrepancies — the issuer applied a 23% rate, the recipient deducted VAT at 8%. Immediately visible inconsistency in KSeF.
  • Related-party transactions at non-market prices — KSeF gives the authority transaction volumes; comparison against a market benchmark is the next verification step.
  • Selective cost invoice recognition — the company selects which cost invoices to recognise as deductible. In KSeF all invoices are visible, so selective recognition requires documented justification.
From my practice: In KSeF readiness reviews the same problem keeps coming up: the invoice exists at the counterparty (I have seen it in their system), but at my client it is booked in a different month or not at all — because it is "awaiting approval". KSeF will end tolerance for delayed approvals. The invoice date in KSeF is the date for the tax authority — regardless of your internal approval process.

Frequently asked questions

Does KSeF increase tax audit risk for compliant taxpayers?
For companies with accurate, consistent records — no. KSeF makes it easier for authorities to verify data, but if your data is consistent with KSeF, an audit will find no grounds to challenge your returns. Risk rises only where there are discrepancies — whether deliberate or the result of process errors.
Can the tax authority open an audit solely on the basis of KSeF data?
KSeF data can be a basis for opening an audit, but the data analysis itself is not an audit. The authority must formally open proceedings. However, automatic KSeF data analysis by KAS systems means that selecting taxpayers for audit becomes significantly more precise and faster.
How does KSeF affect transfer pricing audits?
KSeF gives authorities a full picture of related-party transaction volumes — down to every invoice. This does not eliminate the obligation to maintain TP documentation, but it means that outdated or incomplete documentation is easier to challenge, as the authority now has hard transaction data to compare against.
What to do with cost invoices that should not be tax-deductible?
Book them with the correct non-deductible or limited-deductibility marker. KSeF does not determine tax classification — your documentation and accounting policy do. The fact that an invoice exists in KSeF does not automatically make it deductible. But not booking an invoice that exists in KSeF requires explanation.

What to do before KSeF goes live

  • Conduct an internal review of the last 2–3 years — are there any cost invoices not included in JPK_VAT or booked with a delay?
  • Review transfer pricing documentation — is it current for related-party transactions that will now be fully visible in KSeF?
  • Document cost classification rules (deductible/non-deductible) — each cost category should have a written rule approved by the CFO or tax advisor.
  • Review credit notes from the last 3 years — are they recognised in the correct period on both sides of the transaction?
  • Consult your auditor and tax advisor — a pre-implementation risk assessment is cheaper than explanations after an audit.

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