Draft regulation of the Minister of Finance and Economy on cases where there is no obligation to issue structured

Draft regulation dated 7 August 2025 regarding exemptions from structured invoicing under Poland’s National e-Invoicing System (KSeF)

Summary – Draft Regulation on Structured Invoice Exemptions (KSeF)

Objective

To exempt specific types of economic activity from the obligation to issue structured invoices via KSeF, recognizing the operational and documentation challenges in certain sectors.

Exempted Invoice Types

• Single tickets for toll motorways
• Single tickets for passenger transport (any distance)
• Invoices for en-route air traffic control and surveillance services
• Documents for VAT-exempt services under Article 43(1)(7), (37)–(41) — e.g., banking, financial, and insurance services
• Self-invoicing where the buyer is not identified by a tax ID (NIP)
• Self-invoicing where the authorizing entity is not identified by a tax ID (NIP)

️ Rationale Behind the Exemptions

• Motorway tolls: Avoids imposing new obligations on concessionaires not foreseen in state contracts; preserves safety and traffic flow.
• Passenger transport: High transaction volume and ticket format differ from standard invoices; exclusion supports operational efficiency.
• Air traffic services: Aligns with EUROCONTROL agreements and preserves current documentation practices.
• VAT-exempt services: Maintains continuity for industries like banking and insurance, avoiding disruption post-implementation.
• Self-invoicing without NIP: Addresses practical limitations in identifying parties involved in certain transactions.

Optional Structured Invoicing

§ 3 allows structured invoicing in these cases, even if not required.

Timeline

• Status: Draft under consultation as of 7 August 2025
• Planned Entry into Force: 1 February 2026

Sources

• Deloitte

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• See also
  • E-Invoicing/Real Time Reporting – What can you find on VATupdate.com
  • Worldwide Upcoming E-Invoicing mandates, implementations and changes – Chronological
  • Collection of E-Invoicing Guides – Worldwide – VATupdate
• • Briefing / Comprehensive Guides (incl. podcasts)

• Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE
• Join the LinkedIn Group on ”VAT in the Digital Age” (VIDA), click HERE

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