If you run a sole proprietorship and your income comes from foreign subscription platforms (Twitch, Fanvue), including platforms offering adult content (Onlyfans), the National E-Invoice System (KSEF) has been in effect since April 1, 2026. Although this requirement has been in effect for several months, our observations show that a significant number of creators are completely unaware of it – believing that the KSEF does not apply to them at all.
Why Do OnlyFans Creators Need to Issue Invoices to KSeF? A Short Chain of Rules
First and foremost, as a digital creator You're not selling content to fans. You're providing a service to the platform. Although this is somewhat counterintuitive, it results from EU law, specifically Article 9a of Council Implementing Regulation (EU) No 282/2011According to the provision, a taxpayer participating in the provision of services electronically is deemed to be acting on its own behalf. Due to the judgment issued in the case C-695/20 Fenix International Ltd (British operator OF) we know that the entity operating this type of platform is a service provider to the end user and, consequently, You, as a creator, are a contractor to the platform, not a provider of entertainment services to viewers.
Now that we have established that your contractor is an entrepreneur, the obvious conclusion is – sales must be documented with invoices issued at KSeFYou are obligated to do so by Article 106ga of the VAT Act. For the sake of clarity, let us add that in most cases, OF creators cannot invoke the exemption provided for in paragraph 2 of this provision. Although under the VAT Act you provide your entertainment services outside of Poland (the place of supply is considered the recipient's country of residence), the regulations, specifically Article 106a, point 2, oblige you to issue invoices under Polish rules.
Since the VAT Act obliges you to document sales to platforms with invoices, as a consequence you must use KSeFThere is only one exception to this rule – entrepreneurs invoicing digital platforms for less than PLN 10,000 per month (in total) can still document sales outside the National e-Invoice System until the end of 2026.
Does VAT exemption have any impact on this?
Many digital creators have annual revenues below PLN 240,000 and can therefore benefit from VAT exemptionsContrary to popular belief, VAT registration and the obligation to use the KSeF are two independent systems – no provision of the VAT Act links these two obligations. We wrote about this in more detail in the text Note for non-VAT users – you will also be issuing invoices in KSeF.
Importantly, the definition of sales (Article 2, Section 22 of the VAT Act) mentions, among other things, the provision of services for consideration within the territory of the country. However, this provision does not apply to the provision of services to foreign entities. Consequently, sales to OnlyFans do not, in practice, count towards the PLN 240,000 annual limit – even if you generate several times higher income from working on this platform, you will not exceed the VAT limit (unless, of course, you are conducting sales within the meaning of the VAT Act).
The consequence is simple: regardless of your VAT status, you must issue invoices documenting your earnings on this platform. OnlyFans or any other platform will not ask you for an invoice—it's simply your responsibility.
The PLN 10,000 per month limit trap
As mentioned, there is an exception to the general obligation to use the KSeF system – until the end of December 2026, businesses whose total sales value documented by invoices does not exceed PLN 10,000 in a given month may issue them electronically or in paper form. This is stipulated in Article 145m of the VAT Act. The Ministry of Finance clarified that the PLN 10,000 threshold is calculated by adding the gross amounts of invoices that the taxpayer would be required to issue in the KSeF system. This limit does not include, among other things, consumer invoices, cash register invoices, and receipts with a Tax Identification Number (NIP) up to PLN 450. The invoice for the export of services is included in its entirety in the limit. The ministry's position is therefore favorable for consumer sales and unfavorable for service exports. We wrote about this in more detail in the text 10 PLN per month and you're out of the KSeF. But there are doubts..
In practice, for the creator, this means a simple calculation: if your monthly earnings on the platform exceed the equivalent of PLN 10,000 gross (approximately USD 2,300–2,500), the transitional provision does not protect you and the KSeF applies from April 1, 2026.
Let's emphasize three things:
- Over the limit works from the invoice that exceeded itThis invoice and all subsequent ones must now go through the system.
- There's no going back. Even if revenues fall below the threshold in subsequent months, the obligation remains.
- What counts is income documented by invoices, not withdrawals from the platform.
Receiving invoices in KSeF is a separate issue – this is mandatory for all companies from February 1, 2026, regardless of the limit. If you purchase equipment, assembly services, or advertising from Polish contractors, they issue invoices to you in KSeF – and you must be able to download them. A creator who has never logged into the system simply cannot see their cost invoices.
What should an invoice look like in KSeF for OnlyFans?
As a rule, the basic features of an invoice documenting an entertainment service for a foreign platform are as follows:
- Rate "NP.", i.e. "not subject to taxation in Poland".
- "Reverse charge" annotation – it is worth adding the English “reverse charge” in the comment to the invoice.
- Contents – due to Article 106e paragraph 5 item 2 of the VAT Act, you may not include, among others, the sum of the net sales value broken down by rates, the tax amount and the VAT number (NIP) of the foreign buyer on the invoice documenting the export of services.
- Currency – KseF allows you to issue invoices in foreign currencies, such as euros or dollars. Conversion is made using the National Bank of Poland (NBP) exchange rate from the last business day preceding the tax liability date – typically, this will be the business day preceding the day you issue the invoice.
How do I submit an invoice to OnlyFans if the platform doesn't have access to KSeF?
We hear this question very often. A foreign company doesn't have a Polish Tax Identification Number (NIP) and can't log in to the National Tax Administration (KSeF) to download the document. Fortunately, the answer is essentially simple – After issuing an invoice in KSeF, the document should be made available in an agreed manner, e.g. by sending it by e-mail or uploading it to a designated place.
Importantly, every invoice transferred outside of KSeF must include a QR code, which allows the recipient to verify the document in the system without logging in. In practice, you first send an XML document to KSeF using an invoicing app or your accounting software, then generate a PDF visualization with a QR code and send it to the platform you're currently withdrawing funds from. This brings us to the crux of the problem, which the regulations don't address. Foreign platforms like Twitch and Onlyfans don't coordinate with their creators on how to share invoices. Based on our experience, we suggest:
- Treat the platform rules as a channel agreement. By accepting the terms of service, you also accepted the method of communication – this is the strongest argument available.
- Send PDF visualization with QR code to the address indicated in the creator's panel or via the operator's contact form and archive shipping proofs.
- Keep billing reports from the platform ("Statements" section or equivalent) as documentation of the basis for issuing the invoice and currency conversion.
One more issue worth addressing: reports and summaries generated by the platform are not self-billing within the meaning of Article 106d of the VAT Act. Self-billing requires an agreement specifying the invoice approval procedure. A payroll statement never exempts you from issuing your own invoice.
The invoice issued by the platform Tobie – for your commission – that's a separate matter. It stays outside the KSeF and is accounted for as an import of services, as we discuss in the text. Import of services in VAT – this is what you need to know if you buy ads on Instagram or Facebook.
Can an accounting office issue OnlyFans invoices for me?
The regulations explicitly allow for situations in which a sole proprietor decides to grant access to the KSeF to an external company or individual they employ. Furthermore, there are very few formalities, and the entire process is relatively straightforward.
If you want an accounting firm to process invoices, you grant them permissions in the Certificates and Permissions Module or in the KSeF Taxpayer Application. However, remember two things: the firm cannot register you in the system for you, and you must also remember to activate the permissions after logging in. In practice, granting the accounting firm permissions to your KSeF will take anywhere from a few to several dozen minutes.
What happens if you do not issue invoices in KSeF?
Penalties for not issuing invoices in KSeF are already in force from 1 January 2027 A taxpayer who, despite being required to do so, issues an invoice outside the system may be fined up to 100% of the VAT amount shown on the invoice. For exempt taxpayers – meaning most Onlyfans creators who settle exports of services – this limit is 18,7% of the total amount dueWe're talking about a huge risk, which is worth illustrating with an example. With annual revenues of PLN 200,000, we're talking about a potential fine of around PLN 37,000.
But don't take 2026 as permission. We encounter the attitude "if there are no penalties, then I don't have to." This is a dangerous oversimplification. When conducting inspections, the authority will likely question invoices issued outside the system in violation of the law and raise allegations of unreliable recordkeeping. Even a successful administrative court dispute costs time, money, and frustration.
It's worth noting here that digital creators are particularly vulnerable to scrutiny. Since July 1, 2024, the DAC7 directive has been in effect in Poland. Under its provisions, digital platforms (including Onlyfans, YouTube, and Twitch) are required to report revenue generated by their registered users to the Head of the National Revenue Administration (KAS). By January 31, 2025. 82 operators provided information on over 177 unique individuals and over 115 entities; 83 platforms submitted reports for 2025. We wrote about this in the context of this specific industry in the text Financial data of OnlyFans creators will be sent to Polish tax offices.
The KSeF is another link in the audit chain. Before April 2026, VAT-exempt digital creators who only accounted for the export of services to the UK were practically outside the system – they did not submit JPK_V7 or VAT-EU summary information. Tax authorities received information about such individuals only once a year – in annual returns and DAC7 reports submitted at the end of January. After the KSeF came into effect, the Ministry of Finance gained access to significantly more data, greatly facilitating ongoing taxpayer audits. Discrepancies between KSeF and DAC7 data are very easy to detect – and this is a ready-made pretext for initiating investigations.
Summary
The obligation is already in effect. 2026 is a sanction-free period, but not a period without obligation – and from January 1, 2027, penalties of up to 18,7% of the gross value of invoices issued outside the system by exempt taxpayers will come into effect.
If you earn money on foreign platforms, it is worth doing three things in the coming days: log in to KSeF with a trusted profile, check whether your monthly income exceeds PLN 10,000 gross, and review invoices issued after April 1, 2026 to see if they have been entered into the system.
Business models in this industry can be unusual – collaboration through an agency, multiple platforms simultaneously, an intermediary company, or tax residency outside of Poland. In such cases, the assessment can be ambiguous, and it's worth considering applying for an individual tax ruling, which – unlike someone else's – will actually protect you.
Are you unsure whether the obligation applies to your situation, or do you want to organize your documentation before the office does it for you? Please do not hesitate to contact us – we have been serving digital creators for years and we know the specifics of settlements with foreign platforms.
