e-invoicing in Poland: B2B, B2G, KSeF

The state of Poland’s e-invoicing requirements is in flux. While B2G transactions have required electronic invoices since April 2019, the country’s B2B e-invoicing rules were set to come into effect in July 2024 before a postponement was announced in January 2024. It can be hard to know the latest plans for new obligations, especially considering the possibility of postponements and rule changes.

Staying in the know is vital if your business is to avoid costly penalties.

Continue reading to learn about the current status quo of Poland e-invoicing, including the introduction of a Continuous Transaction Controls (CTC) system via the KSeF platform, as well as what you can expect going forward.

Table of contents

At a glance: Poland e-invoicing

Poland B2G e-invoicing

CTC Type
E-Invoice clearance via KSeF or PEF for B2G transactions carried out with public institutions, initially planned from 1 July 2024, due to the postponement announced in January 2024, the final date is still to be announced

Possible e-invoice issuance both via PEF and KSeF. If B2G, e-invoice will be issued in PEF and automatically transferred to the KSeF in order to assign a KSeF number. The PEF invoice will be visible in the KSeF in the appropriate tab for PEF invoices, and the information about the assigned KSeF number will be available in PEF.

PEF format or KSeF format supporting XML invoices following the logical structure FA_VAT.

eSignature Requirement
A qualified electronic signature is one of the means that taxpayers must use to authenticate in KSeF.

The integrity and authenticity of an invoice are ensured by issuing structured e-invoices via KSeF.

Archiving Requirement
10 years.

Poland B2B e-invoicing

CTC Type
E-Invoice clearance via KSeF for transactions carried out by registered VAT-taxable taxpayers, initially planned from 1 July 2024 and VAT-exempt taxpayers from 1 January 2025, due to the postponement announced in January 2024, the final dates are still to be announced

Centralised network where the e-invoice exchange is processed through the KSeF platform provided by the Ministry of Finance.

XML following the logical structure FA_VAT.

eSignature Requirement
Qualified electronic signature is one of the means that taxpayers must use to authenticate in KSeF.

The integrity and authenticity of an invoice are ensured by issuing structured e-invoices via KSeF.

Archiving Requirement
10 years.

E-invoicing regulations in Poland

Tax compliance is monitored and regulated by the Ministry of Finance, particularly the National Revenue Administration. After implementing the SAF-T changes in Poland in the form of JPKs, the Ministry of Finance is currently revolutionising the invoicing system, introducing the centralised platform Krajowy System E-Faktur (KSeF) for the transmission of structured e-invoices.

Since 2019, public entities in Poland have been mandated to receive and process e-invoices. While currently optional for suppliers of public entities, the transmission of e-invoices will be required for B2G and B2B transactions when the mandate is implemented (this was planned for 1 July 2024 until it was postponed in January 2024).

KSeF Poland: National Electronic Invoicing System

Poland has introduced a national electronic invoicing system called KSeF (Krajowy System e-Faktur), which is a centralised platform for issuing and exchanging electronic invoices with a structured format – currently logical structure FA (2). The go-live date for issuing and receiving invoices via KSeF has been postponed three times since it was originally announced. Once in action, buyers and suppliers in B2B and B2G transactions will be mandated to issue and receive e-invoices through the KSeF platform.

Poland B2B e-invoicing

The issuance of electronic invoices through KSeF has been voluntary for businesses since 1 January 2022, meaning suppliers can issue e-invoices via KSeF. However, buyers can still request to receive them in a different format outside of KSeF.

This will change when e-invoicing via KSeF becomes mandatory for the majority of businesses in Poland – namely registered VAT taxpayers who have fixed establishments on the territory of Poland, and in the later stages to VAT-exempt taxpayers.

Poland B2G e-invoicing

Poland’s own portal, PEF (Platforma Elektronicznego Fakturowania), has been in place since 2019. It aims to centralise and facilitate B2G e-invoice transmission allowing private companies and public bodies to issue and receive electronic invoices. All public entities in Poland have been obliged to register on PEF and receive structured e-invoices since 18 April 2019.

The PEF and KSeF systems will merge when the mandate enters into effect, meaning that e-invoicing in the B2G transactions will be possible both via PEF and KSeF. B2G invoices will also need to receive a KSeF unique ID.

For instance, taxpayers will be able to use features available in KSeF like semantic validation of the e-invoice. Tax authorities will be able to access such invoices, regardless of if they were issued through PEF or KSeF. Therefore, it will be possible to continue issuing B2G invoices via PEF and according to the PEF e-invoice standard.

Timeline: e-invoicing adoption in Poland

The implementation of e-invoicing in Poland has been done in stages. Here is a brief timeline of electronic invoicing’s adoption in the country:

  • October 2021: Testing period of KSeF begins
  • December 2021: Testing period of KSeF ends
  • 1 January 2022: Voluntary use of KSeF commenced
  • 17 June 2022: Poland received the derogatory decision from the VAT Directive to introduce mandatory e-invoicing via KSeF
  • 1 December 2022: Ministry of Finance published draft legislation amending the VAT Act regarding mandatory e-invoicing’s implementation
  • 15 March 2023: Poland publishes second draft law amending the VAT Act, including KSeF changes
  • 16 June 2023: the law amending VAT Act is published by the Ministry of Finance
  • TBD, earlier 1 July 2024: KSeF mandate enters into force for taxpayers
  • TBD, earlier 1 January 2025: KSeF mandate extends to VAT-exempt taxpayers

After the mandatory e-invoicing goes live, the administrative penalties for non-compliance will apply and it will no longer be possible to issue invoices using cash registers, the final date is still to be announced, due to the mandate postponement.

Refer to this blog for an in-depth timeline about e-invoicing in Poland.

Benefits of e-invoicing

While businesses will be legally required to use electronic invoices, there are benefits that taxpayers can enjoy when comparing e-invoices to traditional, paper invoicing. These include:

  • Cost savings: Reducing paper usage, postage and manual labour
  • Time savings: Electronic invoices use standardised formats and automated processes
  • Convenience:  e-invoices increase interoperability across businesses
  • Increased security: Authentication and validation ensure the authenticity of transactions and the according invoices

Learn more about Sovos’ e-invoicing solution.

How to choose the right e-invoicing software in Poland

It’s not enough to accept software that accommodates e-invoicing without adapting it to the often-changing local rules and standards, resulting in the new status quo right as it comes into effect.

While functionality is important, also consider the future when choosing your ideal e-invoicing software provider.

International businesses must keep their eye on the bigger compliance picture, looking beyond local mandates to ensure they are meeting their obligations everywhere they do business. This can be heavy on resources, especially when considering the scope for regulatory updates across multiple jurisdictions.

This is why it is key to work with a global provider such as Sovos.

Future of e-invoicing in Poland

The future of e-invoicing is clear: Poland is working towards a vast implementation. A mandate was planned for 1 July 2024, and while it was postponed in January 2024, it will still become a requirement for many taxpayers. However, the impending implementation of VAT in the Digital Age cannot be forgotten when considering the future of e-invoicing in Poland. Designed to digitise the VAT system in the EU, the proposal may deliver further changes to how established taxpayers in the country do business.

The future of e-invoicing and tax as a whole may be uncertain across the European Union, but Sovos can provide your organisation with the consistency and peace of mind you require. Bookmark this page to remain updated with the latest developments that may affect how you do business.

Additional obligations for VAT compliance in Poland

Keeping on top of the upcoming e-invoicing requirements is important, but it’s also crucial to remember other obligations your business may face when complying with Poland’s VAT regulations.

While adapting to the pressure of implementing e-invoicing, taxpayers need to remain mindful of overall VAT Compliance and the current SAF-T mandate in Poland.

The results of non-compliance can change businesses forever, but Sovos is here to help you stay on top of your obligations.

Setting up e-invoicing in Poland with Sovos

Sovos prides itself in its continuous transaction controls (CTC) software which is purpose-built for customers who must remain on top of tax obligations wherever they do business – even as regulations change in the future.

Taxpayers established in Poland will be starkly aware of the evolving demands of compliance, with B2B and B2G transactions eventually requiring electronic invoices.

As CTCs and e-invoicing rise in prominence globally, there has never been a better time than now to find a compliance partner who understands the rules in play and is already looking ahead at what’s to come. Sovos is the provider you can trust.

The Sovos e-invoicing compliance solution was put to work by Brown-Forman, which looked to ease the burden of compliance from its IT department. Brown-Forman was able to reallocate its resources to core business functions with peace of mind, knowing that Sovos was there to ensure its e-invoicing requirements were being met.

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E-invoicing is mandatory in Poland for B2G transactions, when supplying goods or services to public sector entities that have an obligation to receive e-invoices. This is going to change, when B2B and B2G e-invoicing will be obligatory via KSeF, the final date is still to be announced.

Taxpayers will be mandated to electronically report specific information through KSeF , e.g. in cross-border transactions. In practice, e-invoicing and e-reporting are performed in the same way. The final date of introducing mandatory e-invoicing in Poland is still to be announced, after Ministry of Finance conducts the technical audit of the KSeF system.

Sovos has the first global solution for e-invoicing compliance, including e-reporting functionality.

Poland’s VAT Act mandates that invoices must be issued in two copies, with one being sent to the customer. Invoices cannot be raised before 30 days of the date of the delivery of the goods or services, but also no later than 15 days after the month they were delivered.

VAT invoices must contain numerous details as required by the tax authority, including the likes of:

  • Date of issuance
  • A unique identification number
  • Full name and address of buyer and seller
  • Description of type and quantity of supplied goods, or type and extent of rendered services
  • Date of transaction
  • VAT rate and amount payable

With the implementation of mandatory e-invoicing, additional data points are required to comply with the invoice schema.

Sending and receiving electronic invoicing for B2B and B2G transactions via KSeF in Poland will become mandatory. It was planned to go live on 1 July 2024, though it was postponed in January 2024.

KSeF (Krajowy System e-Faktur) is Poland’s national electronic invoicing system, which is a centralised platform for issuing and exchanging electronic invoices. E-invoices have to follow a structured format, currently logical structure FA (2).

QR codes will be mandatory on the graphical representation of the invoices shared outside of KSeF with the counterparties, invoices issued in the offline modes and VAT RR and VAT KOR RR invoices.

Currently, e-invoicing via KSeF and SAF-T will work parallel with each other in Poland.

Additional resources for e-invoicing compliance

E-invoicing: Your Guide

Use this guide about e-invoicing in Europe to learn more about e-invoicing compliance in general.
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