Where Poland Stands Today
Since January 2022, structured e-invoices can be issued voluntarily via the National e-Invoice System (KSeF). On 30 May 2025 the Ministry of Finance released a new draft legislation package, “KSeF 2.0”confirming that the plan to move from voluntary to mandatory use remains on track.
Confirmed Roll-Out Timeline
- 1 February 2026 – compulsory for taxpayers whose 2024 turnover exceeds PLN 200 million (approximately € 47 million)
- 1 April 2026 – compulsory for all remaining VAT-registered businesses
- 1 January 2027 – deferred deadline for micro-entrepreneurs with monthly invoice turnover below PLN 10.000 (approximately € 2.500) during 2026
Mandatory receipt of KSeF e-invoices, however, starts for everyone on 1 February 2026—even those not yet obliged to issue them.
Technical Foundations: FA(3) & Open API
- FA(3) Logical Structure will replace FA(2) on 1 February 2026, introducing new data fields and validations.
- Open API testing for KSeF 2.0 begins 30 September 2025, giving integrators and large companies four months to verify end-to-end connectivity.
Operational Flexibility: “Offline24” Mode
Taxpayers may issue invoices offline and upload them to KSeF by the end of the next day—known as the offline24 option. This is now permanent, optional and no longer limited by the “specific nature of operations”.
It should be noted that the invoice must be sent to KSeF no later than the next day.
Sharing Invoices Outside KSeF – Broader Recipient Catalogue
The implementing regulation lets sellers deliver invoices outside KSeF—by e-mail or portal download—to:
- Natural persons not engaged in business
- Entities without a Polish tax ID (NIP)
Authentication, QR Codes & Attachments – New Operational Rules
- Invoice-issuer certificates replace today’s one-step token from the end of 2026; applications open 1 November 2025. Certificates will be valid for two years and it will be possible to extend the validation timeline.
- Unified QR code or direct link must appear on every online and offline invoice. If the chosen data format can’t embed the code, it may be sent as a separate link or graphic alongside the invoice.
- Attachments are allowed inside the FA(3) schema.
Transactions & Services Outside the Obligation
The draft lists operations that may remain outside mandatory structured invoicing (e.g., certain cash-register receipts, postcards, VAT RR farmer invoices). These carve-outs clarify where standard PDF or paper can still be used.
Self-Billing – Exemptions from KSeF
Draft executive rules confirm that self-billed invoices will stay outside the National e-Invoice System when either side of the transaction cannot cite a Polish tax ID (NIP). Specifically:
- if a foreign buyer issues an invoice on behalf of a Polish seller but has no Polish NIP, or
- if a foreign seller for whom a Polish taxpayer self-issues invoices has no Polish NIP.
In these cases, the invoice may be created and exchanged by traditional means (PDF, paper, EDI) without going through KSeF.
With the February/April 2026 hard deadlines now locked, and a 2027 cushion for micro-sized firms, companies operating in Poland should intensify testing and governance efforts in 2025.
