The new draft amendment to the Excise Act assumes the introduction of an obligation to keep excise goods records and ledgers exclusively in electronic form starting as early as February 2024. The change involves keeping excise goods records and ledgers electronically in the Central Records of Excise Goods (CEWA), a new central ICT solution that will be made available by the Ministry of Finance to all entities required to keep broadly understood excise documentation.
Only entities that keep records and ledgers electronically in accordance with the current regulations will be able to take advantage of an 18-month transition period to start recording in CEWA.
The introduction of the obligation to keep records in the CEWA system is one of the largest changes in the area of excise duty to date. It will affect a wide range of entities:
- companies operating tax warehouses;
- enterprises with the registered consignor status;
- enterprises with registered consignee status;
- enterprises making intra-community acquisitions of excise goods;
- enterprises keeping records of control over the production, trade and consumption of ethyl alcohol;
- enterprises with the status of intermediary entities;
- enterprises with the status of consuming entities that consume, in the course of their business, products that are exempt due to their intended use, e.g. lubricating oils;
- enterprises keeping records of dried tobacco;
- enterprises with the status of an electricity excise tax payer;
- enterprises with the status of coal intermediaries and gas intermediaries.
The CEWA solution is prepared using client-server technology. Communication with the user will take place by means of a graphical user interface provided via a web browser. In parallel, for the purpose of adding entries to the documentation, the CEWA system will provide an API for receiving standardized electronic files according to the .xml schema. The solution will allow manual entries to be made in the CEWA system provided online. An alternative will be the possibility of sending batch data in bulk according to an appropriate schema.
CEWA will not only collect the uploaded data, but also process it and perform validations.
The financial and accounting systems of these enterprises will require adjustments to keep the required scope of excise records.
It is worth bearing in mind that electronic records must meet specialized requirements. They should:
- enable viewing the content of entries made and provide protection of stored data against distortion or loss;
- allow data corrections to be made only with the annotation of the person making the correction and the date of the correction;
- allow entries and reports to be printed in chronological order;
- prevent deletion of entries.
At All for One Poland, we are analyzing the Ministry’s guidelines in connection with the plans to prepare a solution that will adapt the SAP system to keep the required excise records. We are currently waiting for further information from the Ministry of Finance, in particular the final version of the .xsd schema and the related documentation (so far, the Ministry has released a prototype).
Based on ready-made All for One products, we will also be ready to provide tools for extracting and transferring data from records to the central register. We will develop the solution after publishing the final version of the specification for the process of uploading an XML file to the CEWA application.
We anticipate that for large entrepreneurs this will be a time-consuming process, so we invite you to contact us now to discuss the concept of implementing the solution and to book a date.