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