This blog was last updated on November 5, 2025

Electronic invoicing in Poland via KSeF has undergone a long journey. Providing new expectations for B2B and B2G transactions alike, it is vital for taxpayers to understand what’s to come – though that can be tough when rules and regulations change frequently.

This blog provides a comprehensive timeline of Poland’s advancement towards its e-invoicing mandate, detailing the adjustments your organization should be aware of. The cost of non-compliance reaches beyond financial penalties, so knowledge is vital.

If you’re looking for the current KSeF requirements, visit our overview of e-invoicing in Poland.

If you want to learn more about KSEF 2.0 and how the changes will impact your business, read our FAQs or visit our blog about preparing for Poland’s new e-invoicing landscape.

If you want to see the journey the regulation has been on, and any upcoming changes that could affect your business, keep reading.

Update 23 September 2025 by Kelly Muniz

Ministry of Finance Publishes KSeF 2.0 Implementation Manuals and FAQs

The Polish Ministry of Finance (MoF) has expanded the available KSeF resources by publishing comprehensive new information on their website. This latest release includes detailed FAQs and four implementation manuals to support businesses preparing for the mandatory e-invoicing system scheduled to launch on 1 February 2026.

KSeF 2.0 Manuals

The Ministry has published four complementary manuals to help businesses prepare for the mandatory e-invoicing implementation:

1. “KSeF 2.0 Manual Part I: Getting Started with KSeF” covers initial setup procedures, system registration, authentication methods, and user rights management.
2. “KSeF 2.0 Manual Part II: Issuing and Receiving Invoices in KSeF” focuses on the implementation of the FA(3) invoice structure, technical aspects of invoice submission, and the verification process.
3. “KSeF 2.0 Manual Part III: Additional KSeF Functionalities” explains invoices with attachments, OFFLINE mode functionality, VAT RR invoicing procedures, and self-billing processes.
4. “KSeF 2.0 Manual Part IV: KSeF in Public Sector and Other Authorization Models” addresses invoice issuance and receipt in local government units and government institutions, along with invoicing for enforcement procedures and public procurement.

KSeF 2.0 FAQs

The Ministry has also released extensive FAQs developed in collaboration with businesses, integrators, and stakeholders. The FAQs address fundamental questions about system functionality, technical implementation, authentication methods, and regulatory compliance.

KSeF 2.0 Roadmap

A detailed implementation roadmap is now available on the official KSeF portal. The timeline outlines key preparation stages for the mandatory e-invoicing implementation:

2025:

• 1 September 2025: KSeF 1.0 test environment shutdown
• 24 September 2025: Free KSeF training sessions begin
• 30 September 2025: KSeF 2.0 API made available in the test environment
• 15 October 2025: KSeF 2.0 API made available in pre-production environment
• 1 November 2025: Certificate and Authorization Module (MCU) launch
• 3 November 2025: KSeF 2.0 Taxpayer Application made available in the test environment
• 15 November 2025: KSeF 2.0 Taxpayer Application made available in pre-production environment

2026:

• 1 January 2026: Launch of notification module for invoices with attachments in e-US (electronic tax office platform)
• 26-31 January 2026: Technical maintenance break of KSeF 1.0 production environment
• 1 February 2026: KSeF 2.0 goes live for large businesses and invoice recipients
• 1 April 2026: KSeF 2.0 becomes mandatory for all remaining businesses

2027:

• 1 January 2027: KSeF 2.0 becomes mandatory for previously exempt businesses (up to PLN 10,000 monthly)

With the fast-approaching KSeF mandatory deadlines in 2026, businesses should review these materials as they prepare for the mandate and ensure their invoicing processes meet the new compliance requirements.

Update 1 September 2025 by Kelly Muniz

KSeF 1.0 Test Environment Shut Down

On Friday, August 29, the Polish Ministry of Finance published important news regarding the KSeF (National e-Invoice System).

As of 1 September 2025, the KSeF 1.0 Test environment has been officially shut down. Therefore, from now on no further testing can be conducted in KSeF 1.0. In practice, this means that to become a new KSeF user, taxpayers must wait for the new KSeF 2.0 Test environment once this new environment opens. Users of the current Production environment of KSeF 1.0, can still use it until the maintenance break, which will occur between 26-31 January 2026.

This impacts any taxpayers currently issuing e-invoices in the KSeF 1.0 Testing environment.

Update 5 September 2025 by Kelly Muniz

KSeF 2.0 Updated Draft Regulation on the Use of KSeF

The Polish Ministry of Finance has published an updated version of the draft regulation on the use of the National e-Invoicing System (KSeF). The regulation addresses authentication methods, granting and withdrawing rights in KSeF, KSeF certificate use, invoice marking requirements (QR codes), use of attachments and other technical aspects of the system.

This updated draft primarily clarifies the provisions of the draft published in June this year, rather than introducing significant changes. The new revision mainly offers enhanced descriptions of existing mechanisms, more precise definitions, and clearer explanations, while maintaining the same fundamental approach to KSeF operations and timelines.

Key Clarifications:

KSeF Certificate Validity – Certificates will be valid for up to 2 years from the date of creation or from a starting date specified by the taxpayer, and can be renewed during the validity period.

KSeF Certificate Purposes – More distinct explanation of certificate functions: a) for authentication in the KSeF system and b) for confirmation of issuer identity when issuing invoices in special modes.

Invoice Marking Requirements – Further detailed specifications for marking invoices in different scenarios, requiring different QR code implementations depending on when the invoice is shared with the buyer in relation to KSeF submission. Accordingly, invoices shared outside KSeF before submission will require both an access QR code and a “certificate” QR code to ensure authenticity, while those shared after submission require only the access QR code.

Attachments Notification Process – Refined procedures for submitting and processing notifications regarding the intention to issue and send invoices with attachments to the KSeF system.

The draft regulation continues to undergo the approval process in the Ministry of Finance and has not yet been officially finalized.

Update 28 August 2025 by Kelly Muniz

KSEF 2.0 Act Signed by President and Go-live Timeline Confirmed

Following the parliamentary approval of the KSeF 2.0 Act, Polish President Karol Nawrocki has signed the legislation on 27 August 2025. With this critical approval, which establishes the implementation timeline for Poland’s mandatory e-invoicing system – KSeF, the law now awaits publication in the Polish Journal of Laws (Dziennik Ustaw) to formally enter into force.

Key Implementation Dates Confirmed

The signed legislation maintains the phased approach previously outlined:

• 1 February 2026: Mandatory e-invoicing begins for large businesses with annual turnover exceeding 200 million PLN in 2024
• 1 April 2026: Requirement extends to all other businesses
• Special provisions:until 31 December 2026 businesses with monthly sales under 10,000 PLN are exempt from KSeF compliance

The law will take effect the day after its publication in the Polish Journal of Laws, with certain provisions becoming effective on 1 February 2026, the mandatory KSeF go-live date.

Businesses should now accelerate their implementation plans, as this final approval confirms the mandatory timeline. Additional updates will follow as implementing regulations are published.

Update 6 August 2025 by Kelly Muniz

KSEF 2.0 Act Approved by Parliament

After months of anticipation, the Polish Parliament has approved the KSeF 2.0 Act, which now awaits the President’s signature and official publication in the Polish Journal of Laws. This milestone legislation revises the National e-Invoicing System (Krajowy System e-Faktur, or KSeF), scheduled to become mandatory from February 2026 for the first group of affected taxpayers. The Act addresses key concerns raised by businesses during the consultation period, introducing significant changes to the implementation framework including extended compliance deadlines and new technical requirements.

Key Changes

The KSeF 2.0 legislation introduces important modifications to Poland’s e-invoicing requirements. After a postponement in 2024, the implementation will follow a phased approach based on taxpayer size: large businesses with annual turnover exceeding PLN 200 million (approximately €46 million) in 2024 must comply starting 1 February 2026, all other businesses by 1 April 2026, and businesses with monthly sales under PLN 10,000 (approximately €2,300) have until 1 January 2027.

Most notably, the Act establishes a permanent offline24 mode allowing businesses to issue e-invoices and submit them to KSeF by the next business day. Technical changes include the requirement for potentially placing two QR codes on invoices, the ability to include attachments in the e-invoice schema and the use of internal KSeF certificates. Importantly, certain penalties under the VAT Act and the requirement to include KSeF numbers in payment transfers have been postponed until 2027, giving businesses additional time to adapt.

What’s Next?

Following the President’s signature, two additional regulations in draft form will complete the KSeF 2.0 framework:

1. KSeF Exemptions Regulation: This draft outlines categories of transactions that will be exempt from mandatory e-invoicing requirements, focusing on specific sectors and transaction types, including certain self-billing scenarios.
2. KSeF Usage Rules Regulation: This forthcoming regulation will establish the procedures for granting system access rights, authentication tools, QR code specifications, and rules for registering to issue e-invoices with attachments.

Businesses should be aware of the key implementation dates: API testing availability on 30 September 2025; KSeF certificate issuance beginning 1 November 2025; and KSeF 2.0 production environment go-live on 1 February 2026.

Update 30 June 2025 by Kelly Muniz

KSEF 2.0 Official API Documentation and FA(3) Logical Structure Published

The Polish Ministry of Finance has reached another milestone in the KSeF 2.0 implementation roadmap with the publication of the technical API documentation and FA(3) logical structure on 30 June 2025.

This publication enables businesses and software providers to begin preparations for implementing the KSeF 2.0 in the test environment, which aligns with the previously announced timeline towards mandatory e-invoicing.

Technical Documentation Details

The Ministry of Finance has released comprehensive technical documentation, including:

• FA(3) schema logical structure
• API technical specifications
• Overview of critical changes between KSeF API 1.0 and 2.0
• General explanations of the KSeF 2.0 features

The FA(3) logical structure represents the official version of the mandatory Polish e-invoice schema and was developed through extensive consultation with tax experts, accountants, auditors, software providers, and future users.

Starting 1 February 2026, KSeF 2.0 will become mandatory for all taxpayers subject to the first implementation phase. This date also marks a significant technical transition, as the newly published FA(3) logical structure will officially replace the current FA(2) schema that businesses use in today’s voluntary system.

Confirmed Implementation Timeline

The Ministry has reaffirmed the following implementation roadmap:

• 30 June 2025: API documentation and FA(3) schema published
• 30 September 2025: Test environment for KSeF 2.0 API will be available
• November 2025: Test version of the KSeF Taxpayer Application browser interface
• 1 February 2026: Mandatory KSeF 2.0 implementation begins

As previously announced, the phased implementation will start with larger businesses on February 1, 2026, followed by other taxpayers in April 2026, with the smallest businesses having until January 2027.

What’s Next?

The legislative process for KSeF 2.0 continues to advance, with regulations expected to be finalized in July 2025. This publication marks an important step toward mandatory e-invoicing in Poland and follows the timeline presented in the Ministry’s implementation roadmap.

Update 14 April 2025 by Kelly Muniz

Updates on KSeF e-Invoicing and Revised Draft Law

The Polish Ministry of Finance (MoF) has published an announcement on the current status of legal, technical, and business preparations for the implementation of the mandatory Krajowy System e-Faktur, also known as KSeF e-invoicing system.

After analysing the comments from the November 2024 public consultations, the MoF considered all the key demands submitted by businesses and other stakeholders and published a revised version of the draft proposal of the KSeF simplifying regulations.

The key points of the proposal and of the MoF announcement are the following:

1. Mandatory KSeF Deadlines

The MoF confirmed that the obligation to issue structured electronic invoices through KSeF will be introduced in two stages, with the same dates as previously planned, and with certain changes:

• 1 February 2026:Mandatory for large taxpayers whose total turnover in 2024 (including VAT) exceeds PLN 200 million (approx. €46 million).
• 1 April 2026:Extended to all other taxpayers, except the smallest “digitally excluded” taxpayers whose monthly sales do not exceed PLN 10,000 (approx. €2,500) and single invoices stay below PLN 450 (approx. €100). These smallest entities will have a longer adaptation period and their go-live is scheduled for 1 January 2027.

The turnover threshold for Stage I of KSeF implementation will now be based on 2024 data instead of 2025, giving larger taxpayers earlier clarity on their inclusion in Stage I of KSeF.

VAT RR invoices, which document the purchase of agricultural products from flat-rate farmers, are exempt from the mandatory KSeF requirement, with their optional issuance postponed from 1 February to 1 April 2026.

2. Unified Postponement of Specific Obligations

Several obligations scheduled for mid-to-late 2026 are proposed to be uniformly postponed. This means that until 31 December 2026:

• The option of issuing invoices from cash registers is maintained
• No penalties for errors related to invoicing via KSeF will be applied
• There will be no obligation to provide the KSeF number in payments for e-invoices (including those made using the split payment mechanism)
• There will be no obligation to issue invoices in KSeF for transactions involving small amounts (up to PLN 450 (approx. €100) for a single invoice and up to a total sales value of PLN 10,000 (approx. €2,500) per month)

3. Access to Authentication Certificates

Starting 1 November 2025, taxpayers will be able to apply for invoice issuer certificates required for authentication in the KSeF system and when issuing e-invoices in system failure or “offline24” mode. The technical details will be provided in the API documentation published in June 2025.

4. Permanent “Offline24” Mode

• To mitigate concerns over system outages or delayed responses at the end of accounting periods, the Ministry made improvements to the “Offline24” mode. The main change is that it will be possible to issue invoices in this mode for an indefinite period (the original proposal allowed it until the end of 2026, under certain situations). The Offline24 mode will allow:
• Issuing invoices outside the KSeF system with a QR code when technical difficulties occur (for example, the quality of the transmission network) or when dealing with a foreign entity, a consumer or domestic buyer without a NIP (Polish Tax Identification Number).
• Uploading these invoices to KSeF no later than the next working day.
• Automatic classification of such documents in KSeF as “offline” if the issuance date (field P_1 in FA(3)) precedes the system submission date.

5. QR Code Standardization

The QR code for online mode and offline mode contain different elements. However, to ensure consistency and security, these QR code structures will be unified. QR codes will allow the confirmation that the invoice exists in the KSeF system.

6. KSeF for B2C Transactions

The plan to allow optional issuance of invoices to consumers (B2C) via KSeF remains in place. This simplifies operations for companies engaged in mass invoicing and ensures compatibility with retail practices.

7. E-invoice Attachments

The plan to allow attachments to e-invoices as part of the FA(3) structure remains in place.

8. Updated KSeF 2.0 Implementation Roadmap

• The Roadmap initially published in November last year was updated to include the date of the FA(3) schema publication and postponement of the completion of the legislative process:
• June 2025: Information on the new version of the system, the KSeF 2.0, will be published via the new API documentation and the new FA(3) schema.
• July 2025: Completion of legislative process.
• 30 September 2025: Launch of open API testing environment – possibility to test the API of the KSeF 2.0 in an open manner by all integrators and large companies.
• November 2025: Release of taxpayer authentication certificates and test version of KSeF 2.0 taxpayer application.
• 1 February 2026: KSeF Stage I – KSeF becomes mandatory for companies with turnover > 200 million PLN (based on 2024 data).
• 1 April 2026: KSeF Stage II – KSeF mandatory for all other businesses.
• 31 December 2026: End of the extended deadline for specific obligations (see point 2).

9. New Public Consultation

The revised version of the draft legislation is open for opinions and comments of the general public until 25 April 2025

Update 7 November 2024 by Kelly Muniz

Draft Act and FA(3) Scheme Published

The Polish Ministry of Finance (MoF) has initiated the final consultation process for its National e-Invoicing System (KSeF).

This involves collecting the public’s comments on the new KSeF Draft Act and the updated logical structures FA(3) and FA_RR(1) that have also been published.

The objective of the proposed legislation and updated schemas is to promote necessary changes and simplify certain KSeF obligations, especially considering the topics raised during the multiple consultations held earlier this year.

Main Regulatory amendments proposed by the Draft Act:

• Introduction of mandatory issuance of e-invoices for all taxpayers: the Draft reaffirms the mandatory e-invoicing deadlines previously announced:
  • From 1 February 2026: taxpayers whose sales (including tax) exceeded PLN 200 million (approx. EUR 46 million) in 2025
  • From 1 April 2026: all other entrepreneurs
• Voluntary Issuance of B2C e-invoices:issuing e-invoices to final consumers (B2C) becomes optional. This is currently not allowed in KSeF.
• Alignment of the KSeF Environments:the aim of this alignment is to transition from the current optional KSeF setup to its mandatory version. This involves introducing the technical aspects of mandatory KSeF, before the go-live date, allowing taxpayers to undergo testing in advance. The replacement of the Production environment is planned for Q4 of 2025.
• KSeF Grace period: maintenance of the postponement until 31 July 2026 of application of penalties for non-compliance with KSeF obligations.
• Offline mode:extension of the offline mode until 31 December 2026 so that taxpayers experiencing difficulties in submitting invoices to KSeF may issue outside of KSeF and submit e-invoices to the system within a day of issuance.
• Invoice issuance via cash registers: postponement of this measure, which means maintaining until 31 July 2026 the option to issue invoices via cash registers.
• Inclusion of KSeF number in e–invoice payments: postponement until 31 July 2026 of the requirement to include the KSeF number in all e-invoice payments, including split payment transactions.
• Grace Period for small taxpayers:between 1 April 2026 to 30 September 2026, taxpayers may issue electronic or paper invoices provided that they only issue invoices up to PLN 450 (approx. EUR 100) and that the total value of their monthly sales documented by the invoices is of up to PLN 10,000 (approx. EUR 2300).

Main Technical amendments proposed:

• Possibility of submitting e-invoices with attachments, which will form an integral part of the e-invoice. This will be optional and taxpayers will need to send a notification via API to the authority so that this option can be linked to their NIP (tax identification number).
• Modification of the e-invoice’s logical structure to include the rules for indicating the payment deadline.
• New obligation to ensure access to invoices for entities subordinate to local government units (JST) by including the mark “JST”.
• Introduction of a new “employee” role in the Entity3 node.
• General improvements and other minor modifications to the structure following the earlier consultations.

The MoF has also shared the following KSeF Roadmap:

• Q1 2025: Legislation completion
• Jan 2025: Launch of the KSeF Infoline
• Jun 2025: API documentation release
• Jun-Aug 2025: Limited API testing
• Sep-Dec 2025: Open testing
• Nov 2025: Environment alignment – KSeF Production Environment 2.0
• Feb 2026: Mandatory KSeF

Public Consultation

All changes described above, both in the Draft Act and in the new logical structures, are subject to public consultation and other official formalities before being finally adopted.

Update 26 April 2024 by Marta Sowinska

New E-invoicing Mandate Dates Announced

The Polish Ministry of Finance announced the new official implementation date for mandatory e-invoicing via KSeF during a press conference. The new timeline is as follows:

• 1 February 2026 – for taxpayers whose turnover exceeds PLN 200 million (approx. EUR 46 million) in the preceding year
• 1 April 2026 – for all other taxpayers

The Ministry of Finance emphasized that an earlier implementation date for the mandatory KSeF would not be feasible due to findings from an external technical audit. Consequently, the KSeF system will require a comprehensive architectural rebuild.

Further information concerning technical specifications and necessary legal amendments will be published in the coming months.

Update 23 January 2024 by Marta Sowinska

Electronic invoicing in Poland via KSeF has undergone a long journey. Providing new expectations for B2B and B2G transactions alike, it is vital for taxpayers to understand what’s to come – though that can be tough when rules and regulations change frequently.

This blog provides a comprehensive timeline of Poland’s advancement towards its e-invoicing mandate, detailing the adjustments your organisation should be aware of. The cost of non-compliance reaches beyond financial penalties, so knowledge is vital.

If you’re looking for the current KSeF requirements, visit our overview of e-invoicing in Poland. If you want to see the journey the regulation has been on, and any upcoming changes that could affect your business, keep reading.

Update 19 January 2024 by Marta Sowinska

Poland Postpones E-invoicing Mandate Rollout

Poland’s Ministry of Finance announced today the postponement of its e-invoicing mandate. Originally scheduled for July 2024, the initiative has been postponed indefinitely due to major errors identified in the KSeF system.

The Minister of Finance emphasized that the current technical status of the KSeF system poses substantial challenges, preventing its secure implementation in Poland. Critical errors were identified in the code, affecting overall system functionality and performance of KSeF, prompting the Ministry to take decisive action.

To address these issues, the Ministry of Finance will initiate an external audit to assess the functioning of the KSeF system and evaluate the preparedness for its implementation. The final date for the introduction of mandatory e-invoicing will be contingent upon the results of these audits. In addition, the Ministry will intensify consultations with businesses regarding KSeF.

While expressing full support for the implementation of the KSeF system, the Ministry of Finance reiterated that their priority is to ensure the proper functionality of the system. This commitment stems from the need to secure the economic turnover in the country and avoid situations where taxpayers might be unable to issue e-invoices due to KSeF errors.

Update 5 January 2024 by Marta Sowinska

The regulation amending the scope of data included in the JPK_VAT with a declaration (VAT return) in Poland, has been published in the Official Journal on 4^th January.

The final version of the regulation from 29 December 2023 has been further changed compared to the initial draft, and its final form does not include previously stated obligations to:

• include the special mark “OFF” in the VAT return in respect to invoices issued during KSeF system failure or offline mode, when the technical difficulty to connect with KSeF was on the taxpayer’s side.
• include the special mark “BFK” in the VAT return with respect to invoices issued outside of KSeF.

However, it still includes the obligation to include the unique ID number (numer KSeF) in the VAT return, in case the number has been assigned on the invoice, from:

• 1 July 2024 in the sales and purchase records voluntarily.
• 1 January 2025 in the sales records mandatorily.

The regulation is planned to enter into force from 1 July 2024.

Update: 19 December 2023 by Marta Sowińska

KSeF Technical Specifications Released

The Ministry of Finance has released technical specifications for the KSeF interface in the test environment. This documentation outlines details about QR codes and their associated verification links, it also clarifies information derived from the draft regulation on the use of KSeF that was published in November.

The QR codes serve as visual representations of the verification links and must adhere to the ISO/IEC 18004:2015 standard. Their size and precise placement on printouts are flexible and can be tailored to specific requirements.

Update: 28 November 2023 by Marta Sowińska

Mandatory E-invoicing Draft Acts Published in Poland

On 26 November, the Ministry of Finance published two long-awaited draft acts regarding mandatory e-invoicing via KSeF.

1. The draft regulation on the use of KSeF covers:
   • Verification codes (i.e. QR codes): included on the invoices sent to the buyer outside of KSeF and in the event of system or taxpayer failure to connect with KSeF (offline modes)
   • Offline modes: the scope of data allowing access to invoices in KSeF that were issued in offline mode
   • New authorisations and authentication methods to connect to KSeF, also for VAT RR and VAT RR KOR invoices
2. Amendment to the e-Invoicing Regulation covering:
   • Invoices issued by VAT-exempt taxpayers must include the NIP numbers of both buyer and supplier to align with issuing invoices via KSeF from January 1, 2025

The draft acts are planned to enter into force on 1 July 2024, except for the obligation covering VAT-exempt taxpayers.

In the coming days, the tax authorities will publish the interface technical specifications and description of the technical requirements for the verification codes (i.e. QR codes).

Update: 26 October 2023 by Marta Sowińska

Both the draft regulation and schema specifications are available to view.

Update: 7 August 2023 by Marta Sowińska

Polish President Signs Amendment To VAT Act

On 4 August 2023, the Polish President signed an Act amending the VAT Act and certain other laws which introduces mandatory e-invoicing via KSeF. This means that the e-invoicing mandate will enter into force on 1 July 2024, with no further postponements.

The press information and official announcement from the Ministry of Finance are available to view.

Following the enactment of the law, the Ministry of Finance published a draft regulation amending the regulation on the use of KSeF from 27 December 2021.

Update: 28 July 2023 by Marta Sowińska

Poland’s Draft E-invoicing Law To Move Forward

The Sejm has voted against the Senate’s veto which blocked the draft legislation introducing the national e-invoicing system, KSeF, on the grounds of it being unconstitutional.

Following its adoption by Sejm and pursuant to the draft legislation, the e-invoicing obligation will come into force, as planned, on 1 July 2024, with some exceptions.

As a next step, the draft law will be adopted and enacted in the country after it has been signed by the President.

The results of the voting in Sejm can be found here: Głosowanie nr 39 na 80. posiedzeniu Sejmu – Sejm Rzeczypospolitej Polskiej

Update: 6 July 2023 by Marta Sowińska

Ministry of Finance Publishes Updated Schema

On 29 June 2023, the Ministry of Finance (MoF) published updated schema FA(2) on the ePUAP platform in the Central Repository of Electronic Document Templates (CRWDE), template number (2023/06/29/12648).

Important information about timelines:

• July 2023: The MoF will provide the test environment for the schema FA(2).
• July to August 2023: Both schema versions will apply in the test environment, meaning both schema FA(1) and FA(2)
• 1 September 2023: The MoF will make the production environment available for the schema FA(2)

Read the official announcement for further information.

Update: 10 May 2023 by Marta Sowińska

Poland Adopts Draft E-invoicing Law

On 9 May, the government in Poland adopted a draft law introducing mandatory e-invoicing via KSeF, which will take effect from 1 July 2024. Now the draft law must be approved by Parliament, and the next session is planned for the end of May.

The adoption of this piece of legislation is an essential step, showing that the government is moving forward with the digitalization of the public sector by introducing mandatory e-invoicing via KSeF.

Find out more via the official announcement.

Update: 22 March 2023 by Marta Sowińska

Poland Confirms Changes to E-invoicing Mandate

Poland has published the second draft law amending the VAT Act and certain other laws on the Government Legislation Centre on 15 March 2023.

The amendments mainly confirm previously announced changes, though some additions are worth noting. The essential clarifications include:

1. Scope of the KSeF mandate

• Postponement of the KSeF mandate from 1 January 2024 to 1 July 2024, with some exceptions
• VAT-exempt taxpayers will be in scope from 1 January 2025
  • From 1 January 2025,it will not be possible to issue invoices using cash registers and simplified invoices in the current form
• The mandatory scope of the KSeF system will exclude invoices for B2C transactions, and invoices issued and settled for OSS and IOSS will not be included in the mandate.
• Foreign taxpayers with a fixed establishment in Poland performing activities required to be invoiced according to Polish VAT law will be obliged to issue invoices via KSeF, to the extent that this permanent place of business relates to the supply of goods or services which are invoiced

2. Corrective notes excluded from KSeF

The draft law entirely withdraws the possibility for buyers to issue corrective notes. Buyers cannot propose corrections to the original invoices through or outside KSeF, which the previous draft law presented. Accordingly, changes in the issued invoice can be made only by issuing a corrective invoice.

3. Issuing invoices outside KSeF in case of failure

In line with the previous draft proposal, the current draft law specifies the possibility of issuing e-invoices in offline mode – outside of KSeF in a structured format and delivering to KSeF on the next business day – in case of a failure on the taxpayer side.

The Ministry of Finance will communicate relevant information to the public regarding any maintenance work conducted in KSeF or any system failure. During this time, taxpayers can issue invoices outside of KSeF and deliver them to the buyers in the agreed format.

Such invoices must follow the structured format, be assigned with a QR code and, after the failure ends, be delivered to KSeF within seven days. The date of issuance will be the date stated in the P_1 field, while the buyer’s receipt date will be the date when KSeF assigned the unique ID.

4. QR code

The government has added a new requirement for including a QR code on the invoices issued during a failure of the KSeF system. As previously announced, the QR code must also be included on the invoice visualizations issued outside of KSeF, for example, to foreign buyers and on the VAT RR invoices and corrections to them.

5. Self-billing process under KSeF

The Ministry of Finance responded to feedback about the lack of a self-billing process for cross-border transactions. Therefore, a method of authentication in KSeF for foreign buyers will be included in KSeF, allowing foreign buyers to issue structured invoices on behalf of the suppliers.

6. Exchange rate

The exchange rate used for converting foreign currencies into PLN currency can be maintained from the day preceding the date indicated in the P_1 (date of invoice issuance).

The exchange rate will be calculated based on the date when an e-invoice was issued (stated in the P_1 field), provided that an e-invoice is sent to KSeF no later than the day after the date indicated in the P_1 field.

7. Penalties

Sanctions will apply from 1 January 2025 (previously 1 July 2024) up to 100% of the amount of VAT indicated on the invoice or up to 18.7% of the total amount due shown on the invoice. However, no minimum penalty amount will apply – previously, it was 1000 PLN – approx. 200 EUR.

Next steps for Poland’s KSEF e-invoicing mandate

The draft law is expected to be published in Q3 of 2023, with most provisions applying from 1 July 2024.

Accordingly, the associated final schema FA (2) and FA (RR) are also planned to be published at the end of June or the beginning of July, as announced by the Ministry of Finance during a conference on 16 February 2023. Therefore, we are still waiting for the legislative process to be completed for the e-invoicing mandate to take effect.

Speak with our team if you need more information on the upcoming e-invoicing changes in Poland.

Update: 3 February 2023 by Marta Sowińska

Poland: E-invoicing Mandate Postponement to 1 July 2024

According to an official announcement published by the Ministry of Finance on 2 February 2023, the go-live date of Poland’s mandatory e-invoicing system is now 1 July 2024 – delayed six months from the previous date.

More than a year after the roll-out of the voluntary phase and following extensive testing of the KSeF system by taxpayers, the Ministry of Finance responded to the feedback submitted in the public consultation by delaying the mandate and relaxing certain requirements.

The expected changes are:

• The e-invoicing mandate will be postponed from 1 January 2024 to 1 July 2024
• VAT-exempted taxpayers must comply with the e-invoicing requirements and issue invoices via KSeF from 1 January 2025
• The KSeF system will exclude B2C transactions
• Invoices issued through cash registers and simplified invoices can be issued in their current form until 31 December 2024, meaning such invoices will be in the scope of KSeF from 1 January 2025
• In the case of a technical failure on behalf of the taxpayer, they will be able to issue invoices outside of KSeF and transmit them to the system the next day
• Penalties will be postponed until 1 January 2025 and imposed on taxpayers on a case-by-case basis

Taxpayers should not treat the postponement of the e-invoicing mandate as a reason to pause the implementation process. Instead, treat the delay as an incentive to implement complex legislative and technical requirements before the go-live date and adapt their accounting and invoicing processes considering any errors that may appear.

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