E-Invoicing in Poland

Updated Implementation Timeline and Deadlines

Due to the complexity of the transition, the Ministry of Finance has announced two key deadlines for implementing mandatory e-invoicing in 2026:

Date	Requirement
1 February 2026	Mandatory e-invoicing for VAT taxpayers with 2025 sales exceeding PLN 200 million
1 April 2026	Mandatory e-invoicing for all other VAT-registered businesses

This phased rollout ensures businesses have adequate time to prepare based on their specific invoicing methods.

Scope of the E-Invoicing Mandate

The e-invoicing obligation applies to:

• Polish VAT taxpayers established in Poland
• Fixed establishments of foreign entities in Poland
• B2B transactions, domestic only
• Invoices issued to public institutions (B2G) if using KSeF

The KSeF obligation does not apply to:

• Taxpayers not established in Poland
• Non-VAT taxpayers
• Transactions outside Poland or exempt from VAT

Businesses involved in cross-border activities should remain alert for future expansions of KSeF under the EU’s VAT in the Digital Age (ViDA) initiative.

Voluntary Use and Benefits

Before the 2026 deadline, taxpayers can use KSeF voluntarily. Early adoption offers several advantages:

• Faster VAT refunds (40 days instead of 60)
• No obligation to store paper invoices
• Real-time compliance with VAT rules
• Enhanced transparency and audit readiness
• Reduced administrative burden and printing costs

Structure of Electronic Invoices in Poland

KSeF electronic invoices must follow a logical XML structure defined by the Ministry of Finance. These invoices include:

• Invoice number
• Seller and buyer VAT numbers
• Date of issuance
• Description of goods/services
• Amount and applicable VAT rates
• QR code and KSeF ID for verification
• Invoice correction chain if applicable

Invoices are validated by the system and receive a time-stamped acknowledgment.

How to Generate an E-Invoice via KSeF

Generating a compliant e-invoice in Poland involves several steps:

1. Prepare structured invoice data in XML format. Businesses may use their own ERP or invoicing software that supports the KSeF schema or opt for third-party tools.
2. Authenticate using a qualified electronic signature, trusted profile (Profil Zaufany), or token-based authentication if integrated via API.
3. Transmit the invoice to KSeF via:
   • The KSeF web interface for manual uploads
   • An API connection for automated submissions from accounting or ERP systems
4. Receive confirmation from KSeF, which includes a unique KSeF ID and timestamp validating the invoice.
5. Deliver the invoice reference (KSeF ID or QR code) to the recipient. Businesses may share PDF versions containing the KSeF ID or a QR code that enables verification.

It’s essential to test the system using the Ministry’s sandbox environment before going live, especially if submitting invoices in bulk via API.

Using the KSeF Platform

Invoices can be uploaded to KSeF:

• Manually via the KSeF web interface
• Automatically via API from an invoicing system

The system verifies the XML structure, assigns a KSeF number, and allows the recipient to download the invoice. Invoices not processed through KSeF after the deadline will not be recognized for VAT purposes and may incur penalties.

Compliance Obligations

Businesses are responsible for:

• Adapting internal invoicing systems
• Assigning access rights in KSeF for employees or service providers
• Ensuring continuous access to the KSeF system
• Retaining evidence of correct transmission to KSeF

Non-compliance can result in:

• Penalties up to PLN 1,000 per invoice
• Invalid VAT deductions
• Delayed payments and disputes with customers

Offline24 Mode

The Ministry of Finance has introduced an “offline24 mode,” which permits invoice issuance outside of KSeF in the event of technical problems. Businesses must submit these invoices to KSeF within 24 hours of issuance.

Micro-Business Exemptions

Micro-businesses may continue to issue paper invoices or use fiscal cash registers until January 1, 2027, provided their sales volume and invoice amounts fall below defined thresholds (e.g., invoices not exceeding PLN 450 or monthly sales under PLN 10,000).

Inclusion of KSeF ID in Payments

Although the inclusion of KSeF IDs in bank transfer descriptions was initially planned for earlier implementation, this requirement has also been postponed until January 1, 2027.

KSeF and International Transactions

Currently, the mandate does not apply to cross-border B2B or B2C transactions. However, the Ministry of Finance may expand the system in future phases. Companies operating internationally should plan for long-term adaptation to harmonized digital reporting under EU rules.

Penalty Grace Period

To facilitate a smoother transition, the Ministry of Finance has proposed suspending penalties for non-compliance with KSeF requirements until 01 January 2027. This grace period allows businesses to adjust to the new system without the immediate risk of financial penalties.

For official updates and specifications, visit the Polish Ministry of Finance’s KSeF information portal (in Polish):

https://www.podatki.gov.pl/ksef

Need help preparing for e-invoicing in Poland? Contact us at office@intertax.pl for guidance on system integration, compliance reviews, and full support for KSeF readiness.