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KSeF 2.0 – Ministry of Finance proposes changes

The Ministry of Finance presents the current status of the project solutions and the implementation plan for the mandatory KSeF system.
Author:
Miłosz Saramak
Head of Marketing and Business Development

On April 12, 2025, the Ministry of Finance published on its website the plan and current status of the implementation of the National e-Invoicing System (KSeF). The document takes into account all significant demands submitted by entrepreneurs, tax advisors, accountants, and other stakeholders.

The most important aspect remains unchanged – the implementation schedule:

  • From February 1, 2026, for large taxpayers (those whose sales value in 2024 exceeded PLN 200 million, including VAT)
  • From April 1, 2026, for other entrepreneurs, except for the smallest entities
  • From January 1, 2027, for "digitally excluded" taxpayers, whose transactions involve amounts up to PLN 450 per individual invoice and a total monthly sales value not exceeding PLN 10,000

The Ministry also proposes a single deferral date for KSeF – December 31, 2026 – and has announced the introduction of an additional new mode, Offline24, along with a mobile application

Offline24

Offline24 addresses the demands of entrepreneurs regarding the issuance of invoices in KSeF:

  • it facilitates the issuance of invoices for foreign companies or those not using a Polish NIP (Tax Identification Number), and
  • it provides the possibility to use this solution in cases where there are difficulties in issuing and sending the invoice to the system

This solution allows for the issuance of invoices offline, outside of KSeF, for all taxpayers. These invoices will be marked with a special QR code – such invoices must be promptly submitted to the system, no later than the following day.

Testing of KSeF 2.0

The Ministry announced that on September 30, 2025, the KSeF 2.0 API will be made available in a testing environment, and in November 2025, the KSeF 2.0 Taxpayer Application will be released in a test version. This will provide entrepreneurs with the tools and time necessary to prepare.

Entrepreneurs and interested parties may submit comments and opinions on the project until April 25, 2025, by writing to the Ministry of Finance's secretariat.

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