Background
Poland’s National e-Invoicing System (Krajowy System e-Faktur, or KSeF) is entering its next phase with KSeF 2.0, a mandatory e-invoicing regime designed to modernize VAT compliance and enhance tax transparency. Following extensive consultations in 2024–2025, the Polish Ministry of Finance finalized and published the implementing regulations, including the Exemptions Regulation, which defines transactions and sectors excluded from mandatory e-invoicing requirements. [sovos.com]
Implementation Timeline
- February 1, 2026: Mandatory for large taxpayers (annual turnover > PLN 200 million in 2024).
- April 1, 2026: Mandatory for all other businesses.
- Until January 1, 2027: Micro-businesses with monthly sales below PLN 10,000 (~€2,300) remain exempt. [sovos.com], [sovos.com]
Scope of Exemptions
The published regulation outlines categories where e-invoicing is impractical or technically challenging, granting relief to specific industries and transaction types:
1. Transport and Ticketing
- Single-use toll motorway tickets.
- Passenger transport tickets.
- Air traffic control services charging route fees.
2. Financial and Insurance Services
- Currency and legal tender transactions (excluding collectibles).
- Insurance and reinsurance.
- Credit and loan services.
- Sureties, guarantees, and financial securities.
- Brokerage and intermediation in such services.
3. Cross-Border and Self-Billing Scenarios
- Self-billed invoices where the buyer lacks a Polish tax ID (NIP).
- Transactions involving foreign entities without a Polish establishment, making KSeF authorization impossible.
While these transactions are exempt from mandatory KSeF use, voluntary participation remains possible, allowing businesses to leverage KSeF benefits even when not required. [fiscal-req…ements.com]
Technical and Operational Highlights
- Offline24 Mode: Businesses can issue invoices offline and submit them to KSeF by the next business day.
- QR Code Requirements: Dual QR codes apply in offline or failure modes when invoices are delivered outside KSeF before submission.
- Attachments and FA(3) Schema: The updated FA(3) structure supports invoice attachments and enhanced validation rules. [marosavat.com], [sovos.com]
Briefing document & Podcast: Poland E-Invoicing, E-Reporting and KSeF Mandate – VATupdate
- See also
- 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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