Poland’s Ministry of Finance Issues KSeF 2.0 Draft and Key Revisions

Introduction of KSeF 2.0 Draft Laws: On May 30, 2025, the Polish Ministry of Finance released three draft acts for public review related to the Krajowy System e-Faktur (KSeF) initiative, including a revised draft amending the VAT Act following public consultation. The new laws address various aspects of electronic invoicing, such as corrective invoices, exemptions, and the use of KSeF.
Key Amendments and Provisions: The revised draft includes rules for tax correction periods, expands the scope of entities allowed to receive invoices outside of KSeF, and mandates the inclusion of KSeF IDs on bank transfers. It also removes the limit on single invoices for digitally excluded taxpayers until January 1, 2027, while maintaining a monthly sales limit.
Self-Billing and Authentication Changes: Amendments to the act include provisions for foreign taxpayers to issue self-billed invoices without a Polish NIP number, the introduction of new authentication methods (such as issuer certificates), and updates on marking e-invoices shared outside KSeF. The Ministry aims to finalize the legislation by July 2025, with further technical specifications to be published.

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On May 30, 2025, Poland released the KSeF 2.0 draft law, implementing regulations, technical guidance, and updates, following April’s public consultations for the B2B e-invoicing mandate.
KSeF 2.0 includes new rules on issuer identification, authentication, impact assessments, VAT settlement changes, updated ZAW-FA form, and expanded scope to include natural persons in B2B transactions.
Thresholds for micro-businesses were updated, introducing a simplified PLN 10,000/month limit and easing Offline24 mode rules; certain transactions were clarified as outside KSeF obligations.
Draft FA(3) format and public consultations will continue through June 2025, followed by updated legislation, final schema release, and test timeline ahead of full implementation.
Public testing of KSeF 2.0 API starts September 2025, followed by issuer certificate applications, mobile app testing, and the production environment’s availability by November 2025.
Go-live begins February 1, 2026 for large businesses, expands April 1 for all taxpayers, with additional obligations and penalties phased in through January 2027, including QR code and Offline24 use.

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