The Polish Ministry of Finance has issued four regulations on the National e-Invoice System (KSeF), clarifying when structured invoices are not required, updating rules for simplified invoices, detailing system usage procedures, and amending JPK_VAT reporting to include KSeF invoice numbers and deposit-refund data.
Poland’s Ministry of Finance announced four implementing regulations governing the use of the National e-Invoicing System (Krajowy System e-Faktur – KSeF) on 16 December 2025.
1. Cases Exempt from Structured Invoices
The regulation of 7 December 2025 (Journal of Laws, item 1740) clarifies that issuing structured invoices in KSeF is not required. Exemptions include toll motorway receipts and passenger transport tickets, aviation control fees, and VAT-exempt financial and insurance services, which can be documented using simplified invoices. The regulation also covers self-billing invoices for foreign buyers without a Tax Identification Number (NIP). Additionally, foreign buyers holding an EU VAT number may issue invoices under self-billing for intra-Community supplies.
2. Simplified Invoices
The regulation of 7 December 2025 (Journal of Laws, item 1742) updates the rules for simplified invoices in KSeF. From 1 February 2026, the issuer’s NIP must be included in all simplified invoices issued via KSeF. Simplified invoices issued outside KSeF, for example, to consumers, do not require the NIP. Where applicable, the buyer’s NIP can also be included on the invoice.
3. Rules for Using KSeF
The 12 December 2025 regulation provides detailed rules for using KSeF. It sets out authorisation procedures and user authentication methods, specifies how invoices can be accessed without additional authentication, and defines rules for verifying the authenticity and integrity of invoices issued or sent outside KSeF. The regulation also outlines procedures and technical requirements for invoices with attachments. These rules are reflected in the KSeF technical documentation available to integrators on the Ministry’s website.
4. Updates to JPK_VAT Records
The 12 December 2025 amendment updates JPK_VAT rules to reflect changes introduced by the 5 August 2025 VAT Act amendments. Key changes require KSeF invoice numbers to be included in JPK_VAT records. The amendment also allows other invoices and proofs to be included using specific codes (OFF, BFK, DI) and applies regardless of the issuing method, including offline issuance or system downtime. In addition, the update incorporates the deposit-refund system introduced by the 21 November 2024 packaging law.
Earlier, Poland’s government published legislation establishing KSeF for large taxpayers, effective from 1 February 2026, and for others, effective from 1 April 2026, in the Journal of Laws on 1 September 2025.
