In December 2025 the Ministry of Finance and Economy published four implementing regulations that complete the operational framework for mandatory structured e-invoicing (KSeF). Together, they define the practical rules for using KSeF, when structured e-Invoicing is not required, how simplified invoices work in KSeF, and how KSeF must be reflected in JPK_VAT reporting.
The four implementing regulations and what each changes
1. “Using KSeF” regulation: access model, authentication, verification and attachments- Dz.U. 2025 poz. 1815
This regulation is the system rulebook. It sets out authorization and access management (including the ZAW-FA process), acceptable authentication methods (incl. certificate-based mechanisms), rules for verifying invoices shared outside KSeF, and the framework for invoice attachments.
- User permissions: what types of authorizations exist and how they are granted/revoked, including the ZAW-FA notification template.
- Authentication methods and technical requirements, including identity confirmation (e.g., via certificates).
- How invoices can be shared outside KSeF while still enabling verification of authenticity/integrity.
- Invoice attachments: the regulation sets procedures end-to-end (notification, confirmation, technical constraints). In practice, attachments are positioned as an optional capability designed for complex billing (utilities/telecom/fuels), not as a universal requirement.
2. Exemptions regulation: cases where invoices are not required to be structured – Dz.U. 2025 poz. 1740
This regulation defines specific situations where the obligation to issue structured invoices in KSeF does not apply, including scenarios where the structured FA(3) format is not practical.
The officially listed categories include (among others):
- certain paid motorway toll services documented by a receipt treated as an invoice,
- passenger transport documented by tickets recognized as invoices,
- selected air traffic control / route charge invoicing scenarios,
- some VAT-exempt financial/insurance cases documented via simplified invoices with a narrower dataset,
- defined self-billing scenarios involving “foreign entities” without a Polish NIP (with a specific carve-out where Intra-Community supplies can still be invoiced in KSeF using the EU VAT number).
3. “Invoice Issuance” amendment: simplified invoices aligned with KSeF reality – Dz.U. 2025 poz. 1742
This regulation updates Poland’s invoice issuance rules to fit the KSeF model, with a focus on simplified invoices (faktury uproszczone), including those used by VAT-exempt taxpayers or for VAT-exempt transactions.
A key operational change: from 1 February 2026, simplified invoices issued in KSeF must include the issuer’s NIP, because the system needs it to process and identify the issuer. Outside KSeF, the existing approach can still apply.
4. JPK_VAT reporting update: KSeF numbers and clear markers for “outside KSeF” documents – Dz.U. 2025 poz. 1800
This regulation adapts JPK_VAT so that VAT ledgers can reference KSeF invoices consistently. The design principle is:
- report the KSeF invoice number for invoices issued in KSeF, and
- when the KSeF invoice number is not available at the moment of filing, use dedicated markers in the KSeF node:
- OFF (an offline-issued invoice that does not yet have a KSeF number on filing date),
- BFK (an electronic or paper invoice issued/received outside KSeF),
- DI (a document other than an invoice).
While the regulation is already in force, the first practical application in JPK_VAT is expected with filings for February 2026 (or Q1 for quarterly filers).
What this means for KSeF 2.0 readiness
These four regulations are now the core implementation reference for 2026. Organizations should prioritize: (i) access and delegation governance, (ii) classification of invoice types and exemptions, (iii) simplified invoice rules for KSeF issuance, and (iv) JPK_VAT data mapping for KSeF numbers and “outside KSeF” markers.
