Poland’s Ministry of Finance has announced plans to extend the transitional penalty-free period for the mandatory Krajowy System e-Faktur (KSeF) until 31 December 2027.
Under the proposal announced on 16 September 2026, businesses would have an additional year without financial penalties for errors related to the use of KSeF. As a result, the KSeF penalty regime would effectively apply from 1 January 2028, subject to the required legislative amendment.
The Ministry explained that the additional transition period is intended to give businesses more time to adapt their processes following the phased implementation of mandatory e-invoicing.
KSeF Obligations Remain Mandatory
Importantly, the proposed extension concerns penalties, not the KSeF mandate itself.
Mandatory KSeF e-invoicing has been introduced in phases:
- 1 February 2026: mandatory issuance for businesses whose 2024 sales exceeded PLN 200 million;
- 1 April 2026: mandatory issuance for the remaining businesses, subject to the temporary exemption for the smallest taxpayers;
- 1 January 2027: KSeF becomes mandatory for taxpayers covered by the remaining transitional exemption.
The Ministry has specifically clarified that postponing penalties does not remove the obligation to use KSeF.
Tax Authorities Will Continue to Monitor Compliance
The proposed penalty extension should not be interpreted as a suspension of KSeF compliance requirements.
During 2027, the Polish National Revenue Administration (KAS) will continue to support businesses in applying KSeF correctly and remind taxpayers of their obligations under the VAT legislation.
However, the authorities will also respond to cases where invoices are issued outside KSeF despite the applicable obligation and may examine whether failure to use the system results in inaccurate tax reporting.
Legislative Amendment Still Required
The extension is not yet legally effective.
The Ministry of Finance confirmed that extending the penalty-free period until the end of 2027 requires a legislative amendment and that work on the relevant draft law is now beginning.
Conclusion
The proposed extension would provide businesses with an additional transition period, but it would not change the underlying KSeF obligations.
Companies should therefore continue to comply with the applicable KSeF requirements and monitor the legislative process confirming the extension of the penalty-free period until the end of 2027.
