On 23 May 2025, the Ministry of Finance announced a draft amendment to the Act on the National e-Invoicing System (KSeF), introducing a range of significant changes to the timeline and rules for the mandatory use of electronic invoices in Poland.
The proposed changes result from consultations conducted by the Ministry of Finance in recent years and reflect a number of stakeholder suggestions submitted during this process.
New KSeF implementation timeline
According to the draft act, the obligation to issue invoices via the National e-Invoicing System will be implemented in phases:
- From 1 February 2026 – for large taxpayers whose total sales value (including VAT) for 2024 exceeded PLN 200 million.
- From 1 April 2026 – for all remaining entrepreneurs.
- From 1 January 2027 – for the smallest taxpayers, whose invoices do not exceed PLN 450 and whose monthly sales do not exceed PLN 10,000.
Facilitations and transitional period
A number of facilitative measures for entrepreneurs are planned until the end of 2026:
- The possibility to issue invoices from cash registers will be maintained.
- No penalties will be imposed for errors related to invoicing through KSeF.
- There will be no requirement to include the KSeF invoice number in payments, including in cases involving the split payment mechanism (SPP).
- VAT RR invoices (related to the purchase of agricultural products from flat-rate farmers) will not be subject to mandatory issuance via KSeF. Voluntary issuance of these invoices in the system will be permitted from 1 April 2026 (as opposed to the originally planned 1 February 2026).
Key changes compared to the original proposal
- Introduction of the possibility to issue consumer invoices (B2C).
- Introduction of a rule under which the purchaser is obliged to inform the seller whether they are acting as a VAT taxpayer or a legal entity not registered for VAT.
- Introduction of the ability to issue structured invoices with attachments, provided prior notification is submitted.
- Introduction of the option to issue structured invoices offline, with the obligation to submit them to KSeF on the next business day.
In June 2025, documentation for the new version of the system – KSeF 2.0 – is expected to be published. This will include, among other elements, the new logical structure of the invoice (FA(3)) and the API specification for system integrators and large enterprises.
You can review the draft act and implementing regulations here.
Should you have any questions regarding the impact of KSeF on your company’s
