In the rapidly evolving landscape of global tax compliance, few challenges demand as much immediate attention as the shift to mandatory electronic invoicing. Jurisdictions worldwide are embracing digital transformation, and Poland’s National e-Invoicing System (KSeF) stands out as a prime example of this accelerating trend. For Chief Financial Officers, Tax Directors, ERP Managers, and their teams, understanding and preparing for KSeF is not merely a compliance task – it’s a strategic imperative.
The Polish Ministry of Finance continues to refine the KSeF framework, with the latest draft law published on May 30, 2025. This amendment builds upon earlier proposals, signalling the government’s firm resolve to proceed with the phased rollout of mandatory e-invoicing. It’s a clear call to action for businesses operating in or with Poland.
KSeF: Navigating the Latest Amendments
While the core timelines for KSeF’s mandatory implementation remain largely consistent, the latest draft introduces critical nuances that demand careful attention:
Phased Rollout Confirmed: The obligation to issue invoices via KSeF is set to commence in two main phases. For taxpayers with a turnover exceeding PLN 200 million in 2024, the mandate begins on February 1, 2026. All other entrepreneurs will follow on April 1, 2026. Crucially, micro-entrepreneurs, defined as those with total sales not exceeding PLN 10,000 per month during 2026, have been granted a deferred deadline until January 1, 2027.
Universal Receipt Obligation: It is vital to underscore that regardless of their specific issuance deadline, all businesses will be required to receive purchase invoices through KSeF from the initial mandatory e-invoicing date of February 1, 2026. This means that even if your business falls into the later phases for issuing, your systems must be ready to process incoming KSeF invoices from day one.
Offline24″ Mode Cemented: The Ministry of Finance has permanently introduced the “offline24” mode, allowing taxpayers to issue invoices offline. The key condition is that these invoices must be uploaded to KSeF no later than the end of the next day to receive an identifying number. This flexibility aims to accommodate diverse business needs, but robust internal processes are essential to ensure timely submission.
Streamlined Correction Confirmations: The draft has abandoned the proposal to replace confirmations of receipt for correcting invoices issued outside KSeF with a KSeF number. For structured invoices issued via KSeF, the system itself confirms delivery through the assignment of a KSeF number, removing the need for separate documentation. However, for corrections transmitted outside KSeF, the general principle of requiring seller receipt confirmation for settlement remains, with specific rules for offline or system failure scenarios tying back to KSeF number assignment where applicable. Certain transactions, such as export of goods or intra-Community supply, remain exempt from confirmation requirements.
Expanded Scope for Out-of-System Delivery: A significant facilitation is the expansion of the types of buyers to whom invoices can be sent via traditional channels, outside of KSeF circulation. This now includes individuals not conducting business and entities without Polish VAT IDs (NIPs). This acknowledges the practicalities of dealing with a broader range of recipients.
Authentication and Technical Enhancements: The technical framework is also evolving. The Ministry of Finance is introducing certificates as a new authentication method with a two-year validity, set to be available for download before November 1, 2025. While tokens will remain valid until the end of 2026, certificates are clearly the future. Furthermore, new regulations detail verification codes (QR codes or direct links) for e-invoices and clarify the process for including attachments, with a maximum size of 3MB per attachment.
Foreign Entities and Self-Billing: The latest draft introduces an important exemption for foreign entities that issue self-billing invoices on behalf of a Polish taxpayer but do not use a Polish Tax Identification Number (NIP) for the transaction. Such transactions will not be required to use KSeF…. Conversely, foreign entities using an EU VAT number for a given transaction have the option to use the self-billing procedure within KSeF voluntarily. This acknowledges global transaction complexities and offers much-needed clarity.
Strategic Implications for Your Business
The consistent progress by the Ministry of Finance indicates a strong determination to adhere to the legislative timetable, aiming for completion by July 2025, ahead of the February and April 2026 deadlines. This leaves a relatively short window for comprehensive preparation.
For ERP managers, CFOs, and tax leaders, the time to act is now. This isn’t merely an IT project; it’s a fundamental shift in how your business processes invoicing and manages tax data. We strongly recommend immediate project work focusing on:
Implementation Scheduling: Develop a detailed roadmap that accounts for the phased rollout and the universal obligation to receive invoices from February 2026.
Data Analysis and Mapping: Thoroughly assess your current invoicing data structures and map them to KSeF’s requirements. This often reveals data gaps that need to be addressed proactively.
Internal Process Updates and Contractor Relations: Review and update your internal invoicing, accounts payable, and tax reporting processes. Equally important is communicating and aligning with your contractors on the new KSeF requirements.
The legislative process is dynamic, with regulations undergoing continuous modifications. Constant monitoring of these developments, alongside proactive engagement with the implementation process, will be critical to avoiding compliance pitfalls and potential sanctions. Embracing a robust, future-proof tax technology strategy is no longer optional; it is essential for seamless operations in the digital age.
How RTC Can Support Your Compliance Journey
We understand the immense pressure on businesses to keep pace with evolving digital tax mandates like KSeF. Successfully navigating these complexities requires more than just understanding the rules; it demands intelligent, adaptable technology solutions. This is where RTC offers distinct advantages.
RTC’s platform is built natively on SAP BTP, providing a seamless, scalable, and secure experience without the need for custom ERP developments or package installations, aligning perfectly with SAP’s Clean Core strategy. This foundational strength positions RTC as a powerful ally in your KSeF compliance journey, and indeed, for all your global e-invoicing and digital tax reporting needs. RTC is already integrated with KSeF, ensuring readiness for the upcoming Polish mandate.
Consider the common challenges businesses face in this landscape, and how RTC directly addresses them:
Data Complexity: In an era of diverse data sources and structures, traditional solutions often struggle. RTC efficiently processes various data types, ensuring flexibility and accuracy. It works directly with your raw data, eliminating ERP dependencies, prefilled templates, or the need for add-ons, and is scalable for local regulations, streamlining your data management for KSeF and beyond.
Tax Master Data Compliance: Ensuring your master data meets e-Compliance standards is paramount. RTC helps identify and rectify data gaps, ensuring your data is audit-ready, preventing penalties, and streamlining your reporting processes.
Changing Mandates and Models: Tax regulations are in constant flux. With RTC, you benefit from automatic updates aligned with regulatory changes. The platform evolves seamlessly with new tax rules, providing continuous compliance without requiring internal effort from your IT or tax teams. This means your KSeF solution will remain compliant as Polish regulations continue to be refined.
Validation & Error Handling: Manual validation is prone to errors. RTC ensures error-free submissions through intelligent validation, providing clear, non-technical error messages that users can understand and often fix without requiring IT support. This drastically reduces the time and resources spent on rectifying errors for your KSeF submissions.
Multilingual and Multi-Currency Support: For businesses with international operations, managing invoices and reports across different languages and currencies is a significant hurdle. RTC offers multilingual invoicing and reporting capabilities, coupled with real-time currency conversion, ensuring seamless global compliance.
Multi-Format Invoice Generation: Different countries and industries often require specific invoice formats. RTC’s system supports a wide range of invoice formats, ensuring seamless compatibility with all your customers and suppliers, simplifying global invoice generation including the structured KSeF format.
Backed by an in-house team of regulatory and technical experts, RTC delivers an end-to-end managed service, ensuring you are always up-to-date with legal changes and technical requirements. Whether preparing for ViDA, SAF-T, e-Invoice, e-Reporting, or any other upcoming mandate, RTC provides a robust, future-proof solution.
