Comprehensive Guide to Poland’s National e-Invoicing System (KSeF) Implementation
On 12 April 2025, the Polish Ministry of Finance released a comprehensive update on the National e-Invoicing System (Krajowy System e-Faktur, KSeF), detailing the legal, technical, and operational roadmap toward mandatory electronic invoicing. The system aims to enhance tax compliance, reduce administrative burdens, and foster transparency and efficiency across all business operations.
Implementation Schedule and Obligations
Phase 1: Large Taxpayers
Effective from 1 February 2026, large taxpayers—businesses with total sales exceeding PLN 200 million in 2024 (including VAT)—will be mandated to issue electronic invoices via the KSeF platform.
Phase 2: Other Entrepreneurs
From 1 April 2026, all remaining entrepreneurs, excluding those classified as “digitally excluded,” must comply with mandatory e-Invoicing. Digitally excluded entrepreneurs are defined as those issuing invoices valued at no more than PLN 450 individually or cumulatively up to PLN 10,000 monthly. This smaller subset of taxpayers will have until 1 January 2027 to comply fully with the e-invoicing mandate.
Special Provisions: RR VAT Invoices
RR VAT invoices, issued for purchases of agricultural products from flat-rate farmers, are excluded from mandatory issuance via KSeF. However, from 1 April 2026, their voluntary issuance through the platform becomes available.
New Developments: KSeF 2.0 and Technical Integration
KSeF 2.0 Features
The Ministry has announced significant technological advancements with the introduction of KSeF 2.0, featuring the FA(3) structured invoice template and updated API specifications. These resources will be publicly accessible by June 2025, enabling timely and effective integration.
Technical Timeline
- June 2025: Release of the KSeF 2.0 logical structure (FA(3)) and detailed API documentation.
- 30 September 2025: Open testing begins, allowing integrators and large businesses to adapt and prepare for mandatory compliance.
- November 2025: Availability of the KSeF 2.0 taxpayer application for broader testing and familiarity among entrepreneurs. These test invoices will carry no legal effect.
- 1 February 2026: The official launch date for mandatory issuance by large taxpayers.
Transitional Measures and Support for Taxpayers
Acknowledging the business community’s feedback, the Ministry has introduced several transitional supports to ease the shift to mandatory e-invoicing:
Relief Measures
- No penalties will be enforced for invoicing errors through KSeF until the end of 2026.
- Cash registers may still be used for invoice generation until the end of 2026.
- There is no obligation to include the KSeF number in payments, even within the Split Payment Mechanism (SPM).
Education and Outreach
Tax authorities will provide extensive educational and practical assistance before and during the transition.
Certification and Offline Functionality (Offline24)
Invoice Issuer Certificates
Starting 1 November 2025, businesses may apply for invoice issuer certificates, ensuring authentication within KSeF and maintaining invoicing continuity during system outages.
Offline24 Mode
The introduction of an “Offline24” mode allows invoice issuance even without a stable internet connection. This offline mode supports:
- Efficient invoice issuance to foreign entities or businesses without a NIP number.
- Elimination of delays in invoice generation due to network instability.
- Consistent invoice issue dates, identical to those indicated by the issuer, regardless of the issuing mode.
KSeF Mobile Application
Entrepreneurs will benefit from a dedicated KSeF mobile application, available free of charge on Google Play and the App Store. The app offers functionalities such as:
Features
- Secure invoice issuance, viewing, and sharing.
- Management of multiple seller profiles.
- Creation and storage of buyer and bank account lists.
- Immediate verification of invoice presence within the KSeF.
Upgrade Path
Existing users of the voluntary KSeF system will seamlessly transition to the updated version (KSeF 2.0).
Additional Functionalities and Mass Invoicing
B2C Invoicing
Voluntary issuance of consumer invoices via KSeF, simplifying mass invoicing.
Structured Attachments
Capability to attach structured, detailed annexes directly within invoices. This enhancement addresses complex invoicing needs, allowing for detailed representation of items such as quantities, unit prices, and measures.
Benefits of Adopting the KSeF
The transition to KSeF offers numerous practical advantages:
- Expedited VAT refunds, shortened from the standard 60 days to just 40 days.
- No requirement to physically store invoices or issue duplicates.
- Reduced error potential through standardized invoice formats.
- Enhanced automation capability for invoice data exchange.
- Improved efficiency during tax audits (eliminating the need for JPK_FA submissions).
- Strengthened security with guaranteed immutability and authenticity of invoices.
- Increased transparency and accountability across business transactions.
Public Consultation and Feedback
The Ministry encourages ongoing public consultation and stakeholder engagement. Businesses and taxpayers can submit feedback on the current draft until 25 April 2025 via email to sekretariat.PT@mf.gov.pl. Detailed documentation, including the draft law, impact assessments, and previous consultation feedback, is accessible through the Government Legislation Centre website.
The implementation of the mandatory National e-Invoicing System (KSeF) marks a significant step toward digitalizing Poland’s tax administration, fostering a more efficient, transparent, and business-friendly environment. Entrepreneurs are advised to familiarize themselves with the detailed technical documentation and begin preparations early to ensure a smooth transition to mandatory compliance.
Disclaimer
This article is intended for informational purposes only and is based on the Ministry of Finance’s official communication dated 12 April 2025. It does not constitute legal or tax advice. For personalized guidance regarding your obligations under KSeF, please consult a qualified tax advisor or refer directly to the official publications of the Polish Ministry of Finance.
