North America

Poland: Amendment to Regulation on the Issuance of Invoices Published

Kelly Muniz
December 15, 2025

The Polish Ministry of Finance and Economy has published an amendment to the Regulation on the issuance of invoices. The amendment updates §3 of the regulation, which specifies cases in which invoices may contain a scope of data narrower than that specified in Article 106e of the VAT Act, aligning these rules with KSeF 2.0. The amendment was signed on 7 December 2025 and published in the Journal of Laws on 10 December 2025.

What the Amendment Establishes

The main amendments update §3 of the Regulation on the issuance of invoices to:

  1. Add buyer tax identification number requirements for invoices documenting certain VAT-exempt supplies (such as medical, educational, social, and cultural services), when issued as structured invoices and those issued in offline modes

  2. Update data requirements for invoices issued under the cross-border SME VAT exemption (Art. 113a)

  3. Simplify the wording for transport ticket-invoices, consolidating toll motorway and passenger transport services and removing references to entities acting on behalf of taxpayers

Business Impact

The Invoicing Regulation specifies cases in which invoices may contain a scope of data narrower than that specified in Article 106e of the VAT Act. Businesses issuing such invoices should ensure their invoicing systems are updated to comply with the amended data requirements when issuing structured invoices and in offline modes under KSeF 2.0, following §3 of the Regulation on the issuance of invoices.

The amendment enters into force on 1 February 2026, along with the go-live of KSeF 2.0.

For future updates on Poland and similar developments in other countries, follow our Regulatory Analysis page.

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Author

Kelly Muniz

Kelly Muniz is a Senior Regulatory Counsel at Sovos, specializing in global e-invoicing developments. Originally from Brazil and currently based in Stockholm, Kelly holds a Bachelor’s Degree in Law and worked as a licensed lawyer in her home country. She also earned a Master’s Degree in EU Business Law from Lund University in Sweden.
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