Poland’s Ministry of Finance has published a four-part KSeF 2.0 manual for the national e-invoicing system. The manuals reflect the legal/technical state for the 2026 mandate and will be updated as KSeF 2.0 rolls out.
Getting Started: Scope, Authentication, and Permissions
What it explains:
- KSeF basics & preparation plan: why structured XML is the legal invoice in Poland, who is in scope, and a phased readiness checklist.
- Login & authentication options: Trusted Profile / national e-ID (login.gov), qualified e-signature/e-seal, token (with validity/limits and security rules), and the new KSeF certificate, including how to obtain and manage it.
- Authorisations (uprawnienia): how to grant, delegate, and model access—standard model, internal unit IDs, and dedicated variants for public bodies, VAT groups, bailiffs/enforcement, tax representatives, and issuing VAT RR invoices.
Why it matters: Part I is your onboarding blueprint: pick authentication methods, request certificates, and map who can do what in KSeF before production.
Issuing & Receiving end-to-end Flows and FA(3)
What it explains:
- When an invoice “exists” in KSeF: how the XML is validated, when the KSeF number is assigned, and what that means for the “date of receipt” on the buyer side.
- Operational steps to issue in KSeF: ONLINE flow, handling rejections, visualisation, sending to a wrong buyer, and confirming a transaction.
- How to fill the FA(3) structure correctly: identifiers (NIP formatting, EU/third-country buyer IDs), multi-party/third-party data, public-sector units (JST) and VAT groups (GV), exemptions, foreign trade (WDT/export), self-billing, simplified invoices, advances, corrections, “final/zero” invoices, VAT margin, and more.
Why it matters: Part II is the day-to-day playbook for AP/AR and ERP mapping to validate every FA(3) field and to script what happens after a rejection.
Extra Functions: Attachments, OFFLINE, Self-Billing & Controls
What it explains:
- Invoices with attachments: when you can add an attachment, data limits, how to notify the intention to use attachments, and how the file is made available to buyers.
- OFFLINE issuing modes: declared/emergency and planned cases, deadlines for pushing XML into KSeF afterwards, and QR code rules when sharing documents outside KSeF.
- Special flows & safeguards: VAT RR (and corrections), self-billing, tools to detect/report suspected scam invoices, and the collective payment identifier for grouping payments.
Why it matters: These features cover real-life edge cases (system downtime, utilities/telecom line volumes, agriculture RR).
Sector-specific Models: JST, VAT Groups, Enforcement & Public Procurement
What it explains:
- Local government units (JST): how VAT works for JST, NIP handling, invoices “by and for” JST, and a dedicated authorisation model for complex structures.
- VAT groups (GV): VAT/group NIP specifics, issuing “by and for” the group, and a group-focused authorisation model.
- Bailiffs/enforcement & tax representatives: dedicated permission models and responsibilities.
- Public procurement: issuing in tenders and how KSeF relates to PEF (the B2G platform).
Why it matters: If you’re a public body, in a VAT group, or interact with them, this part is the authoritative source on identifiers, roles, and who signs what.
Release Context & Timeline
- The Ministry released four manuals on the official KSeF site (Parts I–IV) alongside FA(3) materials and job aids (QR rules, UPO elements, numbering).
- Rollout dates: KSeF 2.0 Test environment opens on 30 Sep 2025, production starts 1 Feb 2026; all businesses must be able to receive e-invoices and large taxpayers (2024 sales > PLN 200m) issue e-invoices from Feb 2026; all other taxpayers issue from 1 Apr 2026.
How to Use the Manuals
- Decide your authentication stack (e.g., qualified e-seal + KSeF certificate) and request certificates early.
- Design your authorisation matrix (standard vs. JST/GV/special models) and document who can issue, receive, and delegate.
- Map FA(3) fields end-to-end—including third-party data and special invoice types; test rejection scenarios.
- Prepare OFFLINE & attachment procedures, including QR visualisation and post-event submission deadlines.
- Pilot early in test ahead of the production switch-over.
