On 12 November 2025, the Polish Ministry of Finance released a draft act, focusing specifically on QR code requirements for invoices issued outside the system (offline24 and downtime modes). The aim is not to change how KSeF works, but to narrow when QR codes are needed on invoice printouts and PDFs.
1. New QR Code Rules for Offline24 and Offline Invoices
The draft significantly narrows the obligation to use double QR codes:
Offline24 / offline and domestic buyers with a Polish NIP
For invoices issued in offline24 or offline mode to domestic customers with a Polish NIP number, the document no longer needs to include QR codes. For these buyers, the only legally effective version of the invoice is the one delivered through KSeF, so suppliers can provide a simple transaction confirmation/visualisation instead of a printout with two QR codes.
Unexpected KSeF downtime
If there is an unplanned KSeF outage, invoices may still be issued and sent outside KSeF, including for domestic transactions. In this emergency scenario, the offline invoice must still include both the Offline and Certificate QR codes so that it can later be matched with the KSeF invoice once the system is back online.
Recipients outside KSeF
Where the recipient does not receive invoices via KSeF (for example, foreign entities or B2C customers listed in Article 106gb(4) of the Polish VAT Act), businesses must still be able to issue invoices with two QR codes and ensure their processes and templates support this scenario.
2. Other Technical Amendments in the Draft: Attachments and Specifications
Beyond QR codes, the draft act also proposes to remove the fixed size limit for invoices with structured attachments from the legislation, indicating that these kinds of technical constraints will instead be set in the KSeF interface and schema specifications.
3. Impact on KSeF QR Code Usage
Although the act is still in draft, the current wording does not abolish QR codes; instead, it confines them to offline and non-KSeF scenarios, which should simplify routine domestic B2B invoicing while keeping controls in place where invoices are issued outside KSeF.
