Receiving an advance payment (zaliczka) before the main supply is carried out is one of the most problematic areas when it comes to issuing fiscal receipts (paragon). Under VAT rules, an advance creates a tax point, which raises questions about how the transaction should be documented correctly. This becomes particularly important when the advance is paid by a private individual who does not run a business, because the taxpayer then has to follow the proper procedures for recording it on a cash register (kasa fiskalna). Receipts issued must then be archived – we explain how long to keep receipts.
Documenting advances with a fiscal receipt causes many doubts among business owners, especially as regards when the document should be issued and how it should be recorded. The law regulates these matters clearly, but applying it in practice requires a thorough understanding of how VAT works and of the rules on cash registers. The key is to distinguish between the different ways an advance can be paid and the moment at which the main supply is carried out.
Legal basis for issuing a receipt for an advance
The legal basis for the obligation to issue a fiscal receipt for an advance received is Article 111(1) of the VAT Act, which requires taxpayers selling to private individuals who do not run a business and to flat-rate farmers to keep sales records using cash registers. This provision sets out the general rule that all taxpayers selling goods or providing services to such customers must use the appropriate recording tools, unless they qualify for an exemption under the Regulation of the Minister of Finance of 17 December 2024 on exemptions from the obligation to keep sales records using cash registers (Journal of Laws (Dz.U.) 2024, item 1902, exemptions until 31 December 2027).
Article 111(1) of the VAT Act requires taxpayers to keep sales records using cash registers for transactions with private individuals who do not run a business and with flat-rate farmers. This obligation covers all forms of sale, including receiving advances towards future supplies
This rule is supplemented by Article 111(3a)(1) of the VAT Act, which specifies the obligations of taxpayers keeping sales records using cash registers. Under this provision, taxpayers must issue and hand the buyer a fiscal receipt or an invoice for every sale. The document may be issued on paper or, with the buyer's consent, in electronic form, sent in the way agreed with the buyer. From 1 January 2027 this provision will refer only to the fiscal receipt — invoices may be issued using a cash register (outside KSeF, the National e-Invoicing System) until 31 December 2026 under Article 145n of the VAT Act.
To understand the obligation to issue a receipt for an advance, it is essential to know how a sale is defined for VAT purposes. Under Article 19a(1) of the VAT Act, the tax point arises when goods are supplied or a service is performed. However, Article 19a(8) of the VAT Act significantly modifies this rule: if all or part of the payment is received before the goods are supplied or the service is performed, the tax point arises when that payment is received, in respect of the amount received.
The VAT tax point arises as soon as an advance, prepayment, deposit, instalment or building contribution is received before the main supply. This means the taxpayer must treat the advance received as a taxable event that must be documented in line with the rules on cash registers
This rule also applies where the advance is paid by a private individual who does not run a business. In such circumstances, too, a VAT tax point arises, which automatically means that an appropriate fiscal document must be issued. The law provides no exceptions to this rule based on the legal status of the person paying the advance.
Detailed rules of the regulation on cash registers
The practical aspects of issuing a fiscal receipt for an advance received are regulated in detail by the regulation on cash registers, specifically § 6(1)(1) and (2). Since 1 July 2025 this has been the Regulation of the Minister of Finance of 25 June 2025 on cash registers (Dz.U. 2025, item 845), which replaced the 2019 regulation. These provisions specify when and how the different forms of payment must be recorded, taking into account the specific nature of advances received before the main sale.
Recording advances by form of payment
- Advance in cash - the fiscal receipt must be issued immediately when the cash is received from the customer
- Advance by bank transfer - the receipt must be issued promptly after the payment is credited to the account, no later than at the end of the month
- Advance by post - the same rules apply as for a bank transfer
- Advance to an account in a SKOK (cooperative savings and credit union) - the same deadlines apply as for a bank account
Under § 6(1)(1) of the regulation, taxpayers keeping records must issue and hand the buyer a fiscal receipt when making a sale, no later than when the payment is accepted, regardless of the form of payment. Alternatively, instead of a fiscal receipt, taxpayers may issue an invoice using the cash register and hand it to the buyer. This rule applies to standard sales transactions, where payment takes place at the same time as the supply.
For a sale (§ 6(1)(1) of the regulation), taxpayers may issue an invoice using the cash register instead of a fiscal receipt. The provision on payment received before the sale (§ 6(1)(2)) mentions only the fiscal receipt, and from 1 January 2027 Article 111(3a)(1) of the VAT Act provides for the receipt alone
Much more detailed rules apply where all or part of the payment is received before the sale. § 6(1)(2) of the regulation distinguishes two basic scenarios depending on how the advance is paid. If the advance is received in cash, the taxpayer must issue and hand the buyer a fiscal receipt at the moment it is received, without the customer having to ask for it.
The situation is more complicated for advances received through the post, a bank or a cooperative savings and credit union, into the taxpayer's bank account or the taxpayer's account in a cooperative savings and credit union. In such cases the taxpayer must issue and hand the buyer a fiscal receipt promptly after the payment is credited to the account, but no later than at the end of the month in which it was credited to the taxpayer's account.
The law provides special treatment for advances received by bank transfer. If the main sale is made before the end of the month in which the advance was credited to the account, the receipt must be issued no later than when the sale is made. This rule makes it possible to streamline documentation where the period between receiving the advance and performing the supply is short
When to issue the receipt in practice
Applying the rules on when to issue a fiscal receipt for an advance received requires distinguishing several basic scenarios. The simplest case is when the taxpayer receives the advance in cash directly from the customer. In that case the obligation to issue a receipt arises immediately when the cash is received, and the document must be handed to the customer without undue delay.
In a letter of 5 May 2020 (No. 0114-KDIP1-3.4012.83.2020.2.MT), the Director of National Tax Information (KIS) clarified that payments may be recorded on the cash register immediately after the taxpayer obtains information that they have been received. This means the receipt may be issued without undue delay on the following day or on the first working day after days off, provided the taxpayer obtained the information about the payment in a way that made it impossible to record it immediately.
Situations involving advances received by bank transfer are much more complex. The regulation on cash registers provides for two basic scenarios here, which have significant practical consequences for how the transaction is documented.
Where an advance is received by bank transfer, the key factor is the timing between receiving the advance and performing the main supply. If both events take place in the same calendar month, the taxpayer may use a simplified documentation procedure and issue one receipt for the whole amount when the sale is made
The first scenario applies where the supply was paid in advance into a bank account and is performed within the same calendar month. In such cases the taxpayer may issue one receipt when the sale is made, documenting the whole amount, including the advance received earlier. This solution significantly simplifies record-keeping and removes the need to issue two separate documents.
The second scenario applies where the supply was paid in advance into a bank account but was performed only after the advance had already been recorded on the cash register. In such cases the taxpayer must issue two separate receipts - the first documenting the advance received and the second relating to the main supply. This procedure follows from the need to keep business events in chronological order and to record tax obligations correctly in the relevant settlement periods.
Practical examples
To illustrate how the rules on issuing a fiscal receipt for an advance work in practice, it is worth analysing specific scenarios that may arise in business. The first example is a business owner who on 5 November received an advance from a private individual towards a sale of goods. The advance was credited to the business account on 6 November, and on 29 November the business owner delivered the goods to the customer.
In this case, since the advance was received and the goods were sold in the same calendar month, the business owner may issue one receipt covering the whole amount due on 29 November, i.e. on the day of the main sale. This approach complies with the law and greatly simplifies record-keeping, removing the need for separate documentation for the advance.
When the advance is received and the main supply is performed in the same calendar month, the taxpayer may use the simplified documentation procedure. Issuing one receipt for the whole amount on the day of the sale is fully compliant with the law and recommended for practical reasons
The second example concerns a situation where the same business owner received an advance from a private individual towards a sale of goods on 29 November. The advance was credited to the business account on 30 November, and on 10 December the business owner delivered the goods to the customer. In this case the advance was received and the goods were sold in different settlement periods - November and December.
For this reason, the business owner should document separately, with a receipt, the receipt of the advance and the sale itself. This means issuing a receipt for the advance by the end of November and a separate receipt for the supply in December. This procedure follows from the need to settle tax obligations correctly in the relevant settlement periods.
Practical example: A construction company received by bank transfer (credited to its account on 15 October) an advance of PLN 5,000 towards building a garage. The work was completed on 20 October, and the total value of the service was PLN 15,000. Since both events took place in the same month, the company may issue one receipt for the full amount of PLN 15,000 on the day the work was completed, stating in the description that the amount includes the advance received earlier.
A third possible scenario is where the advance is received in cash directly from the customer. In that case it does not matter in which month the main supply will be performed - the receipt for the advance must be issued immediately when it is received. If the main supply is then performed in the same month, a second receipt will be needed to document the difference between the total value of the supply and the advance received earlier.
Receiving an advance in cash requires a fiscal receipt to be issued immediately, regardless of when the main supply is planned. This rule follows from the need to record all cash transactions on an ongoing basis in line with the rules on cash registers
Comparison of advance payment methods
| Payment method | When to issue the receipt | One receipt possible | Documents required |
|---|---|---|---|
| Cash | Immediately on receipt | No | Fiscal receipt + proof of payment |
| Bank transfer | Promptly after crediting, no later than the end of the month of crediting | Yes, if in the same month | Receipt + bank statement |
| Postal transfer | Promptly after crediting, no later than the end of the month of crediting | Yes, if in the same month | Receipt + post office confirmation |
| Payment to a SKOK | Promptly after crediting, no later than the end of the month of crediting | Yes, if in the same month | Receipt + SKOK statement |
Consequences of non-compliance
Failing to comply with the obligations related to issuing a fiscal receipt for an advance received may have serious financial and administrative consequences for a business owner. The law provides for various sanctions for breaching the rules on cash registers and sales records, which may be applied cumulatively depending on the nature and extent of the irregularities.
Types of sanctions for incorrect recording of advances:
- Fines - under the Fiscal Penal Code (Kodeks karny skarbowy, KKS) for selling without using the cash register or failing to issue a receipt (Article 62 § 4 and 5 KKS)
- Additional tax liabilities - resulting from incorrect VAT settlement
- Default interest - charged on tax arrears
- More frequent inspections - closer supervision of the business by the tax authorities
The basic sanction for selling without using a cash register or failing to issue a receipt is a fine under Article 62 § 4 of the Fiscal Penal Code (up to 180 daily rates), and in a case of lesser gravity — a fine for a fiscal petty offence (Article 62 § 5 KKS), often imposed by a penalty notice of up to five times the minimum wage (Article 48 § 2 KKS). When setting the fine, the offender's financial circumstances and income are taken into account, among other factors (Article 48 § 4 KKS).
In addition, incorrect recording of advances may lead to problems with settling VAT correctly. If the taxpayer has not issued a receipt for an advance received, this may result in the tax point being determined incorrectly, which in turn may lead to errors in VAT returns and related additional tax liabilities. We include cash register sales, advances among them, in the VAT returns of clients who use our accounting services.
Tax inspectors pay particular attention to whether advances are recorded correctly because of their impact on VAT settlement. Irregularities in this area may result not only in penalties for breaching the rules on cash registers, but also in additional tax liabilities together with default interest
It is also worth remembering that incorrect documentation of advances may damage the business owner's credibility in the eyes of the tax authorities. Systematic breaches may lead to more frequent inspections and stricter supervision, which makes running a business considerably more difficult.
Inspections and verification
Tax inspection authorities have a wide range of tools for verifying whether sales, including advances received towards future supplies, are recorded correctly. Inspections in this area may take various forms - from standard tax inspections to specialised cash register inspections carried out by authorised services.
Items verified during an inspection:
- Consistency of records - between the cash register and the accounting documents
- Correct deadlines - for issuing fiscal receipts for advances
- Complete documentation - of all forms of payment
- Compliance with the rules - of the regulation on cash registers
- Correct VAT settlement - in respect of advances received
The following items are subject to particular scrutiny during an inspection:
Inspectors may request access to all documentation relating to receiving and recording advances, including bank statements, accounting documents and cash register reports. Cases where a significant period of time passed between receiving the advance and performing the main supply are analysed particularly closely.
During an inspection, the tax authorities check not only the formal side of recording advances but also whether VAT was settled correctly in substance. Inspectors analyse whether the moment the tax point arose matches the actual settlement of the tax in the VAT returns filed by the taxpayer
If irregularities are found, inspectors may take various measures, ranging from a request for explanations, through assessing additional tax liabilities, to initiating proceedings for a fiscal petty offence or fiscal offence. The severity of the sanctions depends on the scale of the irregularities and on whether the taxpayer acted in good faith or deliberately broke the rules.
Best practice in recording advances
To avoid problems with incorrect recording of advances, business owners should introduce appropriate procedures and internal control systems. It is essential to set clear rules for the different scenarios in which advances are received and to make sure that all staff responsible for serving customers and recording sales are properly trained.
Recommended internal control practices:
- Keeping detailed records - of all advances received, with full documentation
- Regular reconciliations - of advance records with bank documents and cash register reports
- Uniform procedures - regardless of how the advance is received
- Appropriate documentation - making it possible to show that settlements were correct
- Staff training - in operating cash registers and in VAT rules
The first recommended practice is to keep detailed records of all advances received, regardless of their form and value. These records should include the date the advance was received, its amount, the form of payment, the customer's details and the planned date of the main supply. This approach makes it easy to track the status of each advance and ensures that receipts are issued correctly and on time.
The second important practice is to reconcile the advance records regularly with bank documents and cash register reports. Such reconciliations should be carried out at least monthly and documented in a way that allows later verification. This makes it possible to detect any discrepancies quickly and correct them before a tax inspection.
An internal control system that includes regular reconciliation of advance records with bank documents significantly reduces the risk of recording errors. Monthly reconciliation procedures make it possible to detect and correct irregularities on an ongoing basis before they accumulate
The third recommended practice is to apply uniform procedures regardless of how the advance is received. This means the business owner should develop standard procedures both for advances received in cash and for those received by bank transfer. These procedures should be documented and updated regularly whenever the law changes.
The fourth practice is to keep appropriate documentation showing that all advances have been correctly recorded and settled. This documentation should be kept for the period required by law and be easily accessible in the event of an inspection. It is particularly important to keep proof of bank transfers and copies of the fiscal receipts issued.
Technical aspects of cash registers
Correct recording of advances on cash registers also requires taking into account the technical aspects of how these devices work. Modern cash registers offer various functions that make handling advances easier, but using them requires proper configuration and knowledge of the available options.
Many modern cash registers allow special functions to be programmed for handling advances and prepayments. These functions make it possible to issue a receipt for an advance with an appropriate description and to settle that advance later when the main supply is performed. Using such functions makes record-keeping much easier and reduces the risk of errors.
Modern cash registers offer special functions for handling advances, allowing prepayments to be settled automatically when the main supplies are performed. Configuring these functions properly can greatly simplify record-keeping and reduce the risk of accounting errors
Another important technical aspect is classifying advances correctly in the cash register system. Advances should be recorded at the VAT rates that will apply when the main supply is performed. For mixed supplies, covering goods and services subject to different VAT rates, the advance may need to be split accordingly.
Another important element is ensuring the integrity of the data recorded on the cash register. This means making regular backups of the data and protecting it against accidental loss or modification. This is particularly important for advance records, which may be settled over long periods.
A construction company regularly receives advances from individual customers towards future work. Thanks to the right cash register configuration, each advance is automatically classified with the correct VAT rate and description, and the system automatically reminds staff to settle the advance when the main supply is performed. This solution reduces the risk of missing an advance and makes it easier to settle VAT correctly.
