Poland is pressing ahead with its national e-invoicing system, the Krajowy System e-Faktur (KSeF), confirming that mandatory B2B e-invoicing will be rolled out in stages from February 2026, despite prior delays and technical challenges.
The Ministry of Finance (MoF) has now released a refreshed legislative package and clarified key aspects of the mandate in response to public consultation feedback. As businesses begin preparing for the upcoming deadlines, the revised roadmap, technical documentation, and new draft laws signal a clearer path toward implementation.
Here’s what you need to know, what’s changing, what remains, and what your company needs to do to stay compliant.
KSeF Rollout Timeline: Confirmed and Unchanged
Despite speculation around further delays, the MoF has confirmed the original phased rollout schedule:
- 1 February 2026 – Mandatory e-invoicing begins for large taxpayers with 2024 turnover exceeding PLN 200 million (approx. €46 million).
- 1 April 2026 – Extended to all other taxpayers, excluding “digitally excluded” businesses with monthly sales below PLN 10,000 (€2,500) and invoices under PLN 450 (€100). These businesses have until 1 January 2027 to comply.
The Ministry also clarified that Stage I eligibility will be based on 2024 financial data, giving large businesses earlier certainty around their classification.
Invoicing for flat-rate farmers (VAT RR invoices) remains optional until April 2026.
Key Legislative and Technical Milestones
The MoF’s roadmap outlines several key milestones ahead of full implementation:
- June 2025 – Final API documentation and new FA(3) schema expected.
- July 2025 – Completion of the legislative process.
- 30 September 2025 – Open API testing environment launches for integrators and large businesses.
- 1 November 2025 – Authentication certificates become available.
- February–April 2026 – Mandatory KSeF goes live in phases.
- 31 December 2026 – End of the grace period for low-value and digitally excluded entities.
Legislative Updates: What’s New in KSeF 2.0?
The MoF has been active in refining KSeF’s legal and technical foundations. Three significant updates since May 2025 shape how businesses will interact with the platform:
1. Data Processing and GDPR Compliance
Revised legislation ensures that KSeF aligns with EU data protection laws:
- Personal data in B2B invoices will be processed solely for tax control purposes.
- For B2C invoices, which remain optional, data use will be limited and subject to buyer request.
This reaffirms that Poland’s system prioritises transparency, control, and privacy, especially for consumers.
2. “Offline24” Mode Goes Permanent
Originally set to expire in 2026, Offline24 mode is now permanently available for issuing invoices during system outages or for transactions involving:
- Foreign entities or consumers
- Buyers without a Polish NIP
- Technical difficulties
Offline invoices must be uploaded by the next working day. Legal delivery occurs when the system assigns the invoice number, removing prior uncertainty around delivery recognition.
3. New Rules for Attachments and Structured Data
KSeF 2.0 includes detailed rules for structured attachments, aimed at businesses that require more complex invoicing:
- Taxpayers must request authorisation to use attachments.
- Authorisation will have a set validity period, with clear procedures for revocation.
- File size limits apply (max 3 MB, one attachment per invoice).
In addition, invoice issuer certificates will replace token-based authentication from 31 December 2026, enhancing security and standardising access.
4. Revised Conditions for Invoicing Outside KSeF
The updated laws expand the scope of who can receive or send invoices outside KSeF, including:
- Entities without a Polish NIP
- Private individuals not engaged in business
For these cases, taxpayers can continue to use PDFs or paper invoices, provided there’s agreement between seller and buyer.
Hyperlinks to invoices (rather than QR codes) will be permitted where technical limits prevent embedding the link in structured format.
5. Updated B2B Payment Requirements
The updated bill requires taxpayers to include either the KSeF invoice number or a collective payment identifier when making bank transfers, especially relevant for third-party payments.
This aims to improve invoice tracking and payment matching, strengthening transparency across the B2B landscape.
Foreign Entities: Who Is (and Isn’t) Covered?
Foreign businesses registered for VAT in Poland must assess whether they’re obligated to use KSeF.
Here’s the distinction:
- If the entity has no registered office or permanent establishment in Poland, or their Polish establishment is not involved in the specific transaction, KSeF does not apply.
- This follows the EU Council Implementing Decision (EU) 2022/1003, which permits these exemptions.
Importantly, determining whether a foreign entity has a “fixed establishment” in Poland requires case-by-case analysis, and the MoF plans to release guidance on this soon.
FA(3) Schema: Technical Documentation Released
In May 2025, the MoF released the draft FA_VAT (3) schema, which will replace version FA (2) starting 1 February 2026. Alongside it came:
- An information brochure
- Sample invoices
- A full comparison of FA(2) and FA(3)
These materials give software providers and tax teams a clearer view of how to prepare systems and ensure smooth implementation.
Frequently Asked Questions – Clarified
The MoF has also updated the official FAQ section on the KSeF website. Key questions now clarified include:
- When will the implementing regulations be finalised? July 2025 remains the target.
- What about foreign buyers or sellers? The platform allows flexibility for entities without a NIP to receive invoices outside the system, or optionally through KSeF.
- Will self-billing apply? Foreign taxable persons can issue self-billed invoices using their EU VAT number, provided both parties agree.
- What if I’m digitally excluded? The PLN 450 per-invoice exemption is being abolished, but the PLN 10,000 monthly limit remains for exemption until January 2027.
What Businesses Should Do Now
While February 2026 may seem distant, the KSeF compliance curve is steep, especially for large businesses handling high volumes of transactions or complex invoicing.
Here’s what businesses should prioritise:
- Assess KSeF applicability – Determine if your entity or any affiliates are covered, especially if operating cross-border.
- Review system capabilities – Ensure your ERP or invoicing solution can handle FA(3) structure and Offline24 scenarios.
- Request authentication certificates – Available from 1 November 2025, these will be mandatory for system access.
- Engage your software providers – Begin testing once the open API launches in September 2025.
- Monitor regulatory updates – Further clarifications on exemptions, attachments, and structured reporting are expected.
Final Thoughts
Poland’s KSeF initiative is one of the most advanced national e-invoicing programs in the EU. It signals a firm shift toward real-time tax control, enhanced B2B transparency, and fully digitalised VAT reporting.
Despite early delays, the MoF’s renewed momentum and legislative clarity suggest that the system is now on a firm path toward rollout. With the deadlines set and support documentation available, businesses should not wait for last-minute extensions.
Now is the time to prepare, because when February 2026 arrives, compliance won’t be optional.
