July 22, 2026

expert's insight

KSeF in the transport industry vs. payment bottlenecks

Author : Magda Hapeta-Staniek

A carrier completes a transport order, delivers the goods, sends the documents and the invoice, and when the payment deadline passes and they try to clarify the matter with the contractor, they regularly hear the standard reply: "we don't have the invoice" or "please resend it." This is one of the most common and worn-out scenarios used to deliberately delay payments for transport services. The introduction of the National e-Invoicing System (KSeF) is intended to completely eliminate this problem, as a structured invoice registered in the system is deemed legally delivered at the exact moment it is accepted by the government platform. This clarity strengthens the creditor's position both during amicable debt collection negotiations and in potential court proceedings. However, it is worth emphasizing that the digitization of invoices and KSeF apply exclusively to Polish taxpayers, which means that the introduced legal solutions will not automatically affect foreign contractors, with whom disputes over payments in international transport will continue under the old rules.

Digitization of invoices vs. transport documents – digital invoice vs. paper CMR

Despite the revolution in invoicing, the National e-Invoicing System will not automatically cure the problem of payment bottlenecks in the transport industry, as it does not eliminate the fundamental lack of financial liquidity in the TSL supply chain. Instead, the nature and focal point of market disputes will change.

As Marcin Jura explains: "Road transport has always functioned on a rigid link between payment and transport documentation, and standard clauses in transport orders condition the transfer of funds on receiving a correctly issued invoice along with a complete set of documents. After the new regulations enter into force, the original invoice ceases to be a paper document or a PDF file – it becomes an electronic invoice in the system, possessing a unique KSeF identifier. However, this change does not go hand in hand with operational realities because transport documentation crucial for calculating payment terms – such as the international CMR consignment note, national consignment note, delivery receipts, or customs documents – still functions entirely outside the tax system, most often in traditional physical circulation. Although KSeF regulations provide a technical option to attach files to invoices, this concept does not cover transport documents, which must still be delivered via a separate route."

Debt collection in transport – interpretive conflicts and outdated transport contracts

In practice, a potential and deep source of new conflicts between carriers and freight forwarders is already visible. Domestic road carriers will firmly argue that the e-invoice was successfully delivered on the day of its registration in KSeF and that the contractual payment term should be counted from that date. Obligors, on the other hand, will start to argue that the payment term has not yet begun to run because they have not received the complete set of transport documents in the required form, and a structured invoice alone, without a physical CMR note, does not trigger the payment procedure. The situation is highly complicated by the fact that most transport orders and carriage contracts functioning on the market are templates used for years, which completely ignore KSeF realities and do not specify what an "invoice" actually is in the new legal order. This raises serious questions about whether, in the event of discrepancies, the literal content of the signed order takes precedence or the mandatory provisions on structured invoices. In the near future, the TSL industry faces a painful process of adjusting contracts, and until then, an increase in interpretive disputes over payment bottlenecks is practically inevitable.

How to secure financial liquidity in TSL – receivables management in the KSeF era

From the perspective of effective receivables management in transport, the digitization of invoices should be treated only as a supporting tool, not a ready-made solution to the problem of delayed payments. For transport companies, it is absolutely crucial to immediately organize the clauses in their orders and clearly define the role played by the KSeF identifier and how the delivery of paper or electronic transport documents (e-CMR) affects the actual running of the payment term.

As our expert, Marcin Jura, summarizes: "KSeF does not end disputes in the transport industry; it merely shifts their focal point. Instead of the previous discussions about whether the invoice was delivered to the contractor at all, we will increasingly and more fiercely dispute what its 'receipt' actually means in the context of contractual provisions and the accompanying traditional transport documentation."

Our advice: Update your transport order templates now and introduce clauses that precisely separate the moment of delivery of the e-invoice in KSeF from the deadline for delivering CMR documents. Clearly defining these rules in the contract is the most effective protection for your financial liquidity against new interpretive conflicts.