Polish authorities are advancing at an accelerated pace toward the implementation of the National e-Invoicing System (KSeF 2.0).
Following the second public consultation on the draft simplifying the KSeF system in April, a set of draft regulations were published in late May. On 17 June, a new version of these drafts was published, and the Polish Council of Ministers has now officially approved the draft regulation amending the VAT Act. The legislation will now move to Parliament for approval.
The recently published drafts contain several critical provisions that will shape KSeF 2.0 implementation:
Official Timeline Unchanged
The phased implementation schedule remains confirmed with mandatory adoption beginning 1 February 2026 for taxpayers with sales exceeding PLN 200 million (approx. €46 million) in 2024. All other entrepreneurs must comply starting 1 April 2026, while the smallest taxpayers with monthly sales under PLN 10,000 (approx. €2,300) have until 1 January 2027 to implement the system.
Key Implementation Dates
The Ministry of Finance has confirmed the roadmap published in April, with the following key milestones:
· June 2025: Publication of logical structure FA(3) and API documentation
· July 2025: Completion of legislation
· September 2025: Open API tests for KSeF 2.0
· November 2025: Provision of certificates and test version of KSeF 2.0 Taxpayer Application
Key Features and Provisions in the Draft Regulations
Offline24 Mode
The drafts introduce a permanent “offline24” mode for electronic invoicing. This will allow businesses to issue structured invoices without real-time connection to KSeF and upload them to the platform by the next business day. For domestic B2B transactions, buyers will need to receive these invoices directly through the KSeF system.
Authentication Methods and Transitional Provisions
The system will support multiple authentication methods during transition, with tokens remaining valid until 31 December 2026 and trusted signatures until 31 March 2026. After these dates, authentication will rely on qualified electronic signatures, seals, and the new KSeF certificates. Further details will be presented in the interface specifications.
E-invoices with Attachments
This proposed feature is designed primarily for utility providers, telecommunications services, and fuel suppliers, but will be available to all taxpayers. Prior registration with tax authorities will be required.
B2C E-invoicing
The legislation proposes making B2C e-invoicing optional through KSeF. Businesses will be able to issue consumer e-invoices via KSeF but must provide them outside the system if requested. Addressing data privacy concerns, the Ministry notes that B2C e-invoicing is not expected to be widely adopted by entrepreneurs. Consumer data in KSeF will be used solely for verifying supplier tax compliance, not for profiling consumers. All data will be subject to strict access controls and appropriate GDPR protections.
Collective Identifier
While the original version of the draft regulation simplifying the KSeF limited this identifier to cover multiple e-invoices for a single recipient only, the newer version will allow the possibility of assigning one collective identifier to e-invoices issued to multiple recipients.
Several key requirements are proposed to be delayed until 31 December 2026 to ease the transition to KSeF:
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Cash register invoices may continue to be issued outside the system
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The obligation to include KSeF e-invoice numbers in payment transfers
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Financial penalties for errors related to KSeF
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No fiscal criminal proceedings will be initiated for specific KSeF-related failures
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Micro-entrepreneurs with monthly sales under 10,000 PLN (approx. €2,300) may continue using traditional invoicing (simplified from earlier draft that included a 450 PLN (approx. €105) per-invoice limit)
What’s Next?
Following the government’s approval, the draft legislation will now move to Parliament (Sejm) for the next stage of the legislative process.
The next steps in the implementation of KSeF include the publication of technical documentation, planned system testing, issuance of certificates, and deployment of test environments.
Businesses should begin reviewing their invoicing systems and processes to assess KSeF readiness. Companies should evaluate authentication requirements and determine which implementation phase applies to their operations.
Want to understand more about e-invoicing requirements in Poland and how they will impact your business? Read our Sovos e-invoicing in Poland: B2B, B2G, KSeF dedicated webpage.
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