Mandatory KSeF from January 1, 2024

The Ministry of Finance has published a draft law introducing the mandatory issuance of invoices in structured form as of January 1st, 2024.
Gerard Goliasz
TAX Specialist

According to the statutory definition - a structured invoice (hereinafter also: e-invoice), is an invoice in electronic form, issued via the National e-Invoice System (KSeF), with an assigned number to identify the invoice in the system.

In practice, e-invoices are new types of invoices, which do not have a traditional form ( paper or electronic file, such as PDF). These invoices have the form of a file in XML format, generated in accordance with the logical structure published by the Ministry of Finance - the so-called XSD Scheme. An e-invoice is issued by sending it to the KSeF, which verifies its formal correctness and, after positive validation, assigns it a unique number.

It is the assignment of this number that is tantamount to: the issuance of an invoice entering legal circulation, at which point it also becomes available for download by the recipient.


In practice, e-invoices are produced in the aforementioned electronic form through the taxpayer's financial and accounting software, which should also provide the ability to send the invoice to KSeF. Sending and downloading of e-invoices is provided by a publicly available API.

Under the proposed regulations, as of January 1st, 2024, VAT taxpayers with a registered office or permanent place of business in Poland will be required to issue invoices in structured form. However, foreign taxpayers who are only registered for VAT purposes in Poland will be exempt from this obligation. The requirement will also cover transactions with consumers and foreign taxpayers.

These regulations are scheduled to come into force on January 1st, 2024, but it is highly recommended to adjust your organization to these requirements as of today.

The draft law is available here.

KR Group supports its current and future clients in these preparations, offering both substantive and technological support.

Download PDF file here.

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