Is invoice without VAT correct?

One of most common questions: is invoice without VAT correct? Answer is: yes, it is correct—provided taxpayer meets specific VAT exemption requirements.

Invoice without VAT is issued by taxpayers entitled to VAT exemption. This may result from two main reasons: entity exemption (because of turnover size) or item exemption (because of activity type).

Entity exemption: PLN 240k limit in 2026

Entity exemption is right for taxpayers whose revenue doesn't exceed specified limit. It's promotion for small firms to not burden them with VAT obligations.

What limit applies in 2026?

From January 1, 2026, entity exemption limit increased from PLN 200k to PLN 240k annually. This means every entrepreneur whose previous year revenue didn't exceed this amount can issue invoices without VAT.

However, buyer of goods or services can request VAT invoice from VAT-exempt taxpayer. Must do so within three months from purchase date or service completion. If buyer is VAT taxpayer wanting to deduct VAT, should make this request.

Item exemption: VAT-exempt services

Item exemption is right to issue invoice without VAT regardless of revenue size. Applies to specific service types indicated in VAT law.

Which services are VAT-exempt?

Article 43 of VAT law lists wide catalog of exempt services:

If you conduct activity covered by item exemption, can issue invoices without VAT regardless of revenue size.

What elements must invoice without VAT contain?

Invoice without VAT should contain almost all same elements as standard invoice, except VAT field. Here are mandatory elements:

Mandatory information on invoice without VAT

• Seller data: Name, address, tax number (if any)
• Buyer data: Name, address (not always buyer TIN for exempt)
• Invoice number: Unique identifier
• Issue date: Day, month, year
• Service/goods delivery date: If different from issue
• Goods/service description: Detailed description of subject
• Unit and total price: Net amounts (without VAT)
• VAT exemption indication: For example "VAT exempt—art. 113" or "VAT exempt"

Must buyer TIN be provided?

For entity-exempt taxpayer (exempt due to revenue limit) no obligation to provide buyer TIN on invoice. This simplification results from finance ministry regulation.

For item exemption (e.g., medical services), requirements may differ—verify for specific industry.

Must invoice without VAT be sent to KSeF?

From April 1, 2026 all invoices must be issued electronically in KSeF system (National e-Invoice System). This includes invoices without VAT from VAT-exempt taxpayers.

VAT-exempt taxpayers must:

• Register in KSeF system
• Issue invoices through system
• Archive invoices per requirements
• Report to tax office

Should invoice without VAT contain exemption basis?

This is common question. Answer depends on exemption type.

For entity exemption (revenue limit)

Not mandatory to include exemption basis information (e.g., "art. 113 of VAT law"). However, many firms voluntarily add this for clarity.

For item exemption (art. 43)

For services exempt under article 43 also not required to show exemption basis on invoice itself. Service type (e.g., "Medical consultation", "Training course") clearly indicates exemption.

Practical examples of invoices without VAT

Here are typical scenarios where invoice without VAT is correct:

Example 1: Freelancer under PLN 240k limit

Freelance graphic designer with PLN 180k annual revenue issues invoice for graphic project. Since below PLN 240k limit, can issue invoice without VAT. Invoice contains: date, service description, price, contractor data and exemption indication.

Example 2: Doctor in private practice

Doctor running private practice issues invoice for medical consultation. Since medical services are item-exempt (art. 43), invoice without VAT is correct regardless of revenue.

Example 3: Private school

Private school issues invoice to parents for educational service. Since education is item-exempt, invoice without VAT is fine.

What happens after exceeding PLN 240k limit?

If annual revenue exceeds PLN 240k limit, entrepreneur must register for VAT starting next tax year.

After registering for VAT, entrepreneur must:

• Issue VAT invoices (with calculated tax)
• Maintain detailed VAT records
• File VAT declarations (JPK_V7M) monthly or quarterly
• Settle VAT with tax office

FAQ: Most common questions

Can I ask buyer for refund on invoice without VAT?

No, that would be illegal. If you issued invoice without VAT (being entitled to do so), buyer must accept it in that form. If buyer is VAT taxpayer and needs VAT invoice, must request within 3 months.

Is invoice without VAT valid for employee on salary?

Yes, invoice without VAT is valid for any buyer—both VAT taxpayers and individuals or salaried employees. Employee can receive invoice without VAT without problem.

Must I always issue invoice without VAT?

No. If you are VAT-exempt (by entity or item), all invoices should be without VAT. Cannot mix—issue to some clients without VAT, others with VAT.

What if VAT taxpayer buyer requests VAT invoice and I'm exempt?

Then you have options: file VAT registration request (if you want), or inform buyer that due to exemption, cannot issue VAT invoice. Buyer should consult their accountant on VAT deduction possibilities.

Can I issue invoices without VAT through KSeF from April 2026?

Yes, KSeF system handles invoices without VAT. VAT-exempt taxpayers will issue non-VAT invoices exactly like before, but in electronic form through KSeF.

Can VAT-exempt taxpayer voluntarily register?

Yes, entity-exempt taxpayer can voluntarily register for VAT if believes this will be beneficial (e.g., to deduct VAT on expenses).