In 2026, your store must be ready for KSeF, proper handling of foreign sales, and well-organized returns. The key is correct OSS/IOSS procedures, JPK_V7 with the WSTO_EE marker, and compliance with BDO and DAC7.
What changes for online stores in 2026?
Mandatory KSeF starts on 1.02.2026 for the largest companies and 1.04.2026 for others; micro-enterprises up to 10k PLN/month from 1.01.2027. Prepare your invoicing, correction, and returns processes.
KSeF milestones
- 1.02.2026 – mandatory for companies with sales ≥ 200m PLN in 2024 (ksef.podatki.gov.pl).
- 1.04.2026 – mandatory for other entrepreneurs; exception for micro-enterprises until 1.01.2027 (ksef.podatki.gov.pl).
- Until 31.01.2026 – KSeF is optional; check instructions on biznes.gov.pl.
How to account for domestic and foreign sales in e-commerce?
For the EU, you use WSTO and the OSS procedure; for imports up to 150 EUR – IOSS. After exceeding 10,000 EUR annually, you tax in the country of consumption.
WSTO/OSS/IOSS – key rules
- 10,000 EUR (42,000 PLN) limit for total B2C sales to the EU – after exceeding, VAT is based on the customer’s country rates (MF explanations, MF Q&A).
- OSS – quarterly settlement in Poland for B2C sales to the EU (podatki.gov.pl).
- IOSS – import up to 150 EUR, simplified settlements (podatki.gov.pl).
| Situation | What to use | Where to pay VAT |
|---|---|---|
| Sale from Poland to EU consumer, below limit | WSTO_EE in JPK | Poland or voluntarily OSS |
| Sale from Poland to EU consumer, over limit | OSS | Consumer’s country (via OSS) |
| B2C import ≤ 150 EUR | IOSS | Consumer’s country (via IOSS) |
Tip: Make VAT payments for OSS/IOSS according to the Ministry of Finance instructions (podatki.gov.pl).
When is OSS not enough for sales from foreign warehouses?
When goods are shipped from a warehouse in another EU country, a local VAT obligation arises. OSS does not replace local registration for domestic sales in the warehouse’s country.
Fulfillment, FBA, 3PL – tax consequences
- Moving goods to a warehouse in another EU country requires a local VAT number for domestic sales from that country.
- You can still use OSS for shipments from Poland if the transport originates there.
How to document returns and complaints in an online store?
The consumer has 14 days to withdraw; payment refund within 14 days of the declaration. You make VAT adjustments according to the rules for invoices/receipts.
Legal basis and practice
- Right of withdrawal 14 days and effects of refund – UOKiK: deadlines, UOKiK: effect.
- VAT adjustment for returns – keep proof of return, make adjustments on the accounting document; rules stem from the VAT Act and cash register regulations.
- From 2026, you issue invoice corrections in KSeF; ensure a procedure for quick corrections and customer notifications (ksef.podatki.gov.pl).
Are e-receipts and e-invoices sufficient in e-commerce?
Yes, if you meet the requirements for cash registers and KSeF. For an invoice issued for a receipt, the B2B buyer must provide their NIP on the receipt.
Minimum documentation requirements
- E-receipt permitted by regulations on cash registers (Dz.U. 2025 poz. 845, technical requirements).
- Invoice for a receipt only with NIP on the receipt; a receipt up to 450 PLN with NIP is a simplified invoice (gov.pl).
- In KSeF, you send invoices and corrections in structured format (VAT amendments for KSeF).
Which JPK_V7 codes apply to e-commerce?
You mark WSTO sales in the records as WSTO_EE. Remember about GTU where applicable, and the current JPK structure.
Codes and structures
- JPK_V7 instructions and current 2025 schema – podatki.gov.pl, JPK_V7M(3) schema.
- WSTO_EE – code for WSTO and TBE services after the e-commerce package changes (MF explanations).
How to account for gift cards and vouchers in the store?
For a single-purpose voucher, VAT arises upon transfer of the voucher. For a multi-purpose voucher, you account for VAT only upon redemption.
Definitions from the VAT Act
- Single-purpose voucher (SPV) and multi-purpose voucher (MPV) – definitions and tax implications in Art. 2, 8a, 8b of the VAT Act (text of the Act).
Does selling through marketplaces involve additional obligations?
Yes, platform operators report seller data under DAC7. You must ensure complete data and consistency in settlements.
DAC7 – what it means for you
- Poland implemented DAC7 from 1.07.2024; reporting is handled by KAS (National Revenue Administration) (podatki.gov.pl).
- Scope and exclusions (less than 30 transactions and 2,000 EUR) – podatki.gov.pl.
Does e-commerce have environmental obligations (BDO/ROP/deposits)?
Yes, by introducing products in packaging, you register in BDO, report, and pay fees. Check the regulations and rates.
BDO in practice for a store
- Register and rules – BDO, registration rules.
- Act on packaging and packaging waste – consolidated text 2025 (Dz.U. 2025 poz. 870); product fee rates – Dz.U. 2025 poz. 988.
How to arrange accounting processes for KSeF, OSS, and returns?
Establish clear rules for data, document flow, and PSP reconciliations. Automate the link between the order, payment, and invoice.
Minimum e-commerce “workflow”
- Order → payment → KSeF invoice (B2B) or receipt/e-receipt (B2C).
- Shipment → delivery confirmation → revenue recognition.
- Return/withdrawal → return document → VAT adjustment → refund ≤ 14 days.
- Cross-border sale → WSTO_EE report → OSS/IOSS declaration and VAT payment.
What does it look like in practice? Progress Holding’s experience
Based on over 500 e-commerce settlements we conducted in 2023–2025, we have gathered the most common sources of errors and ready-made corrective actions.
Our data: Most common errors in e-commerce
| Error | Consequence | How we fix it |
|---|---|---|
| Failure to segregate sales from foreign warehouses | Wrong VAT rate and arrears | Supply chain audit, local registration, corrections |
| Incorrect WSTO_EE codes in JPK | Record non-compliance | ERP→JPK mapping, tests on MF schema |
| Delayed corrections for returns | Risk of interest | RMA procedure + automatic correction in KSeF |
| Incomplete data for DAC7 | KAS inquiries, payment blocks | Seller KYC checklists and marketplace verification |
| Lack of packaging register for BDO | Administrative fines | Implementation of mass records and annual reports |
Progress Holding implements KSeF, handles OSS/IOSS settlements, and prepares returns processes. We provide e-commerce audits and ongoing accounting services.
Frequently asked questions
I sell to the EU below 10,000 EUR. Do I need OSS?
No. You can settle in Poland, but OSS can be simpler as you approach the limit (see MF materials).
I ship from a German FBA warehouse. Is OSS enough?
No. For sales from a German warehouse, you need German VAT for domestic transactions in DE.
Can I send customers only e-receipts and e-invoices?
Yes, if your cash register and system meet the requirements and customer consent. Remember KSeF for invoices from 2026.
How do I mark WSTO sales in JPK_V7?
With the WSTO_EE code in the records. Check the current JPK schema on podatki.gov.pl.
When do I recognize VAT for vouchers?
For SPV, upon sale of the voucher; for MPV, upon redemption by the customer (VAT Act).
What data can marketplaces provide about me to KAS?
Identification data and sales values, with exceptions for very small scale (DAC7 on podatki.gov.pl).
Does every store need to be in BDO?
If you “introduce” packaging to the market, which is usually the case in e-commerce – yes. Registration via BDO.
The most important conclusion: organize your invoicing in KSeF, WSTO_EE records, and returns procedures, and you will avoid corrections and penalties. Need professional support? Contact Progress Holding: +48 603 232 418 or office@progressholding.pl. We handle OSS/IOSS registrations, KSeF implementations, and accounting services for e-commerce in Poland.
Sources and legal acts (selection): KSeF; biznes.gov.pl on KSeF; OSS/IOSS – podatki.gov.pl; VAT e-commerce explanations (MF); OSS/IOSS Payments; UOKiK deadlines, UOKiK effects; Invoices for receipts; Regulation on cash registers 2025; VAT Act; JPK_V7; DAC7 – podatki.gov.pl; BDO; Act on packaging 2025; Product fee rates 2025.
Progress Holding services: KSeF 2.0 implementation, OSS/IOSS registrations, e-commerce accounting, WSTO/FBA audit, BDO support, and returns policy. Schedule a consultation: +48 603 232 418, office@progressholding.pl.
