Poland’s Ministry of Finance announced the commencement of final consultations regarding the mandatory implementation of the National e-Invoicing System (Krajowy System e-Faktur – KSeF).
The National e-Invoicing System was initially scheduled to become mandatory on 1 July 2024, but its implementation had been postponed to 1 February 2026. Additionally, some related obligations have been deferred until the end of July 2026.
Proposed legal solutions regarding KSeF
The final proposal under review stipulates that the KSeF will become mandatory for all taxpayers starting from:
1. Introduction of mandatory KSeF for all taxpayers (for active taxpayers and taxpayers exempt from VAT), taking into account the following stages:
- from 1 February 2026 for entrepreneurs whose sales value (including tax amount) exceeded PLN 200 million in 2025,
- from 1 April 2026 for other entrepreneurs.
2. Postponement for an additional six months, i.e., until July 31, 2026, of the introduction of certain other solutions, such as:
- Postponement of the requirement to provide the KSeF number in e-invoice payments. This also applies to invoices for which payment is made using the split payment mechanism;
- maintaining an additional KSeF deferral about invoices issued from cash registers;
- maintaining an additional postponement of the deadline for penalties for non-compliance with KSeF obligations.
3. Enable offline mode by the end of 2026 for all taxpayers.
4. Allowing the issuance of consumer invoices in KSeF.
5. Providing legal solutions that meet the objective of equalisation of KSeF environments. This involves implementing technical features of the mandatory system before the regulations requiring taxpayers to issue invoices in KSeF come into effect.
6. Allowing “digitally excluded” taxpayers—those issuing a small number and value of invoices—to continue using their current invoicing format during the transitional period, which lasts until 30 September 2026.
