The Polish Ministry of Finance (MoF) has published an announcement on the current status of legal, technical, and business preparations for the implementation of the mandatory Krajowy System e-Faktur, also known as KSeF e-invoicing system.
After analysing the comments from the November 2024 public consultations, the MoF considered all the key demands submitted by businesses and other stakeholders and published a revised version of the draft proposal of the KSeF simplifying regulations.
The key points of the proposal and of the MoF announcement are the following:
1. Mandatory KSeF Deadlines
The MoF confirmed that the obligation to issue structured electronic invoices through KSeF will be introduced in two stages, with the same dates as previously planned, and with certain changes:
- 1 February 2026: Mandatory for large taxpayers whose total turnover in 2024 (including VAT) exceeds PLN 200 million (approx. €46 million).
- 1 April 2026: Extended to all other taxpayers, except the smallest “digitally excluded” taxpayers whose monthly sales do not exceed PLN 10,000 (approx. €2,500) and single invoices stay below PLN 450 (approx. €100). These smallest entities will have a longer adaptation period and their go-live is scheduled for 1 January 2027.
The turnover threshold for Stage I of KSeF implementation will now be based on 2024 data instead of 2025, giving larger taxpayers earlier clarity on their inclusion in Stage I of KSeF.
VAT RR invoices, which document the purchase of agricultural products from flat-rate farmers, are exempt from the mandatory KSeF requirement, with their optional issuance postponed from 1 February to 1 April 2026.
2. Unified Postponement of Specific Obligations
Several obligations scheduled for mid-to-late 2026 are proposed to be uniformly postponed. This means that until 31 December 2026:
- The option of issuing invoices from cash registers is maintained
- No penalties for errors related to invoicing via KSeF will be applied
- There will be no obligation to provide the KSeF number in payments for e-invoices (including those made using the split payment mechanism)
- There will be no obligation to issue invoices in KSeF for transactions involving small amounts (up to PLN 450 (approx. €100) for a single invoice and up to a total sales value of PLN 10,000 (approx. €2,500) per month)
3. Access to Authentication Certificates
Starting 1 November 2025, taxpayers will be able to apply for invoice issuer certificates required for authentication in the KSeF system and when issuing e-invoices in system failure or “offline24” mode. The technical details will be provided in the API documentation published in June 2025.
4. Permanent “Offline24” Mode
To mitigate concerns over system outages or delayed responses at the end of accounting periods, the Ministry made improvements to the “Offline24” mode. The main change is that it will be possible to issue invoices in this mode for an indefinite period (the original proposal allowed it until the end of 2026, under certain situations). The Offline24 mode will allow:
- Issuing invoices outside the KSeF system with a QR code when technical difficulties occur (for example, the quality of the transmission network) or when dealing with a foreign entity, a consumer or domestic buyer without a NIP (Polish Tax Identification Number).
- Uploading these invoices to KSeF no later than the next working day.
- Automatic classification of such documents in KSeF as “offline” if the issuance date (field P_1 in FA(3)) precedes the system submission date.
5. QR Code Standardization
The QR code for online mode and offline mode contain different elements. However, to ensure consistency and security, these QR code structures will be unified. QR codes will allow the confirmation that the invoice exists in the KSeF system.
6. KSeF for B2C Transactions
The plan to allow optional issuance of invoices to consumers (B2C) via KSeF remains in place. This simplifies operations for companies engaged in mass invoicing and ensures compatibility with retail practices.
7. E-invoice Attachments
The plan to allow attachments to e-invoices as part of the FA(3) structure remains in place.
8. Updated KSeF 2.0 Implementation Roadmap
The Roadmap initially published in November last year was updated to include the date of the FA(3) schema publication and postponement of the completion of the legislative process:
- June 2025: Information on the new version of the system, the KSeF 2.0, will be published via the new API documentation and the new FA(3) schema.
- July 2025: Completion of legislative process.
- 30 September 2025: Launch of open API testing environment – possibility to test the API of the KSeF 2.0 in an open manner by all integrators and large companies.
- November 2025: Release of taxpayer authentication certificates and test version of KSeF 2.0 taxpayer application.
- 1 February 2026: KSeF Stage I – KSeF becomes mandatory for companies with turnover > 200 million PLN (based on 2024 data).
- 1 April 2026: KSeF Stage II – KSeF mandatory for all other businesses.
- 31 December 2026: End of the extended deadline for specific obligations (see point 2).
9. New Public Consultation
The revised version of the draft legislation is open for opinions and comments of the general public until 25 April 2025 which can be submitted to sekretariat.PT@mf.gov.pl.
Want to understand more about e-invoicing requirements in Poland and how it will impact your business? Read our Sovos e-invoicing in Poland: B2B, B2G, KSeF dedicated webpage.
