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
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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.
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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.
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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.
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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.
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.
