The Polish Minister of Finance and Economy has signed the Regulation on the use of the National e-Invoicing System (Krajowy System e-Faktur, KSeF), which is now awaiting the final step – publication in the Polish Journal of Laws (Dziennik Ustaw).
This regulation is a key implementing act for the mandatory KSeF 2.0 framework, replacing the previous 2021 regulation that governed the voluntary KSeF period.
What the Regulation Covers
The regulation provides detailed rules for using KSeF, including:
Permissions and Authorizations: Defines the types of permissions to use KSeF and procedures for granting and revoking them, including the use of the ZAW-FA notification form.
Authentication Methods: Defines the methods for authenticating in KSeF – electronic identification via the national node, qualified electronic signature, qualified electronic seal, and the new KSeF certificate. Transitional provisions allow continued use of tokens (until 31 December 2026) and Trusted Profile (until 31 March 2026).
QR Codes: Specifies two types of QR codes – Type I (verification) for invoices shared outside KSeF, allowing recipients to verify and access the invoice in the system; and Type II (certificate code) for offline mode invoices, which uses the KSeF certificate to confirm issuer identity when the invoice is delivered outside KSeF before being submitted to the system.
Invoices with Attachments: Sets out procedures for invoices with attachments, from notification of intent to issue, through confirmation of eligibility, to technical requirements.
Key Changes from the Draft Version
The final regulation includes several refinements compared to the November 2025 draft, including:
-
Invoices with attachments: The “complex data” condition is now embedded directly in the regulatory definition itself
-
Self-billing and VAT RR permissions: Expanded to explicitly include natural persons and coverage for offline/failure mode invoices
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VAT RR application date: New provision confirms VAT RR functionality applies from 1 April 2026
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One-person notification limit: Clarified that current authorized person must be revoked before designating a new one via ZAW-FA
Key Dates in the Regulation
|
Date |
Provision |
|---|---|
|
1 January 2026 |
Taxpayers can submit notifications to issue invoices with attachments |
|
1 February 2026 |
Main regulation enters into force, aligned with the KSeF 2.0 go-live |
|
31 March 2026 |
Last day to use the Trusted Profile for KSeF authentication |
|
1 April 2026 |
National node authentication available; VAT RR provisions take effect |
|
1 January 2027 |
Tokens can no longer be used for KSeF authentication |
Current Status
The regulation was signed on 12 December 2025. The signed version is awaiting publication in the Journal of Laws. The signed regulation and ZAW-FA form template are available as attachments to the Ministry announcement.
For future updates on Poland and similar developments in other countries, follow our Regulatory Analysis page.
