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Poland’s National E-Invoicing System (KSEF): Recent Changes Effective February 2026

2 weeks ago
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This briefing document summarizes the key themes, ideas, and facts surrounding the implementation of the National e-Invoicing System (KSeF 2.0) in Poland, drawing from the provided sources. KSeF 2.0 is a mandatory e-invoicing system aimed at modernizing VAT compliance and increasing tax transparency. Key themes include the implementation timeline, technical requirements, exemptions, changes to VAT reporting (JPK_VAT), correction rules, and practical considerations for businesses.

1. Implementation Timeline and Key Dates:

  • February 1, 2026: Mandatory for large taxpayers (sales exceeding 200 million PLN in 2024). “From February 1, 2026, large VAT taxpayers (over PLN 200 million sales in 2024) must issue invoices via the National e-Invoice System (KSeF); all others from April 1, 2026.”
  • April 1, 2026: Mandatory for all other VAT-registered businesses in Poland.
  • January 1, 2027: Cash register receipts with a buyer NIP can no longer be issued, and must be handled through KSeF.
  • December 22, 2025: Production contract for API KSeF 2.0 frozen to ensure stability. “On December 22, 2025, the production contract for API KSeF 2.0 will be frozen by the Ministry of Finance.”
  • December 10, 2025: Module for Certificates and Permissions (MCU) enables the generation of KSeF 2.0 authentication tokens.
  • January 1, 2026: Module to register intention to submit invoices with attachments goes live via the e-Tax Office.
  • March 31, 2026: End of the transitional period where “trusted signatures” can be used for authentication.

The Ministry of Finance has stated that the implementation deadlines will not be postponed. “The Ministry of Finance states that companies have had enough time to prepare and that no postponement of the deadline is planned.”

2. Scope and Mandatory Use:

  • Mandatory for most B2B transactions: “Starting 1 February 2026, all entities in Poland engaged in B2B transactions must use the National e-Invoice System (KSeF) for the exchange of invoices.”
  • All taxpayers must receive invoices via KSeF from February 1, 2026. “All taxpayers must receive invoices via KSeF from February 1, 2026.”
  • Sales value in 2024 determines the implementation date: “The obligation to issue invoices via KSeF depends on the gross sales value achieved in 2024, not 2025.”
  • Threshold for KSeF Usage: Until December 31, 2026, invoices outside KSeF are allowed if monthly sales do not exceed PLN 10,000. “Until December 31, 2026, invoices outside KSeF are allowed if monthly sales on such invoices do not exceed 10,000 PLN (including VAT); exceeding this triggers mandatory KSeF use from that invoice onward.”
  • Voluntary usage: Structured invoices can be issued voluntarily even when not obligatory. “The regulation allows for structured invoices to be issued even when not obligatory.”

3. Key Features and Technical Requirements:

  • FA(3) Structure: KSeF 2.0 will use the new logical structure FA(3) for invoices. “KSeF 2.0 introduces a new logical structure (FA(3)).”
  • API Freeze: The production contract for the KSeF 2.0 API will be frozen on December 22, 2025, to ensure stability for integrators. “From December 22, 2025, the Ministry of Finance will freeze the production contract for the KSeF 2.0 API.”
  • Attachments: KSeF 2.0 allows for structured invoices with attachments for complex transactions, but these attachments can only contain tax-related or strictly related data. “From 1 February 2026, KSeF 2.0 allows issuing and sending e‑invoices with a structured XML attachment (element “Zalacznik” in FA(3)), mainly for transactions with complex data on units of measure, quantities or unit prices.” Registration is required to issue invoices with attachments.
  • Authentication Tokens: New authentication tokens compatible with KSeF 2.0 will be available from December 10, 2025. Tokens from KSeF 1.0 will not be migrated. “KSeF 1.0 tokens are not compatible with KSeF 2.0 and will not be migrated.”
  • MCU (Module for Certificates and Permissions): This module allows businesses to generate authentication tokens and manage access rights.
  • QR Codes: Invoices may contain one or two QR codes: one linking to the document in KSeF and another validating the issuer’s certificate and authenticity. However, experts warn that these are vulnerable to fraud, so buyers must use KSeF itself to verify invoices.
  • Offline Modes: KSeF 2.0 introduces an offline24 mode allowing invoices to be issued offline with mandatory submission to the system by the next business day. A separate emergency mode will be available for total system outages.
  • Address Updates: New service addresses for KSeF are being rolled out, with integrators required to switch to the new addresses in test environments by January 10, 2026. “New addresses will be provided starting December 15, 2025, with a requirement for integrators to switch to the new addresses in test environments by January 10, 2026.”

4. Exemptions:

Certain transactions are exempt from mandatory KSeF e-invoicing. These include:

  • Toll motorway services: Documented by invoices containing less data than standard VAT invoices. “Exemptions include: toll highway services (NIP receipts).”
  • Passenger transport services: (Rail, road, sea, air, etc.) with single-use tickets containing limited data. “Exemptions include … passenger transport tickets.”
  • Air traffic control services: Billed by EUROCONTROL.
  • VAT-exempt financial and insurance services.
  • Self-billed invoices where the buyer lacks a Polish tax ID (NIP). “Self-billed invoices where the buyer lacks a Polish tax ID (NIP).”
  • Transactions involving foreign entities without a Polish establishment.

5. Changes to JPK_VAT Reporting:

  • KSeF Number Requirement: JPK_VAT records must include the KSeF invoice number for invoices issued in the KSeF system. “JPK_VAT records must include the KSeF invoice number for invoices issued in the KSeF system.”
  • Specific Markers: Invoices issued outside KSeF must be marked with specific codes in the JPK_VAT records (OFF, BFK, DI). “New important invoice designations: OFF (invoice without KSeF number), BFK (electronic or paper invoice), DI (other document issued via KSeF).”
  • Reporting Timeline: The new JPK_VAT regulation applies to the JPK_VAT declaration for February 2026 (or Q1 2026 for quarterly taxpayers). “The new regulation applies to the JPK_VAT declaration for February 2026 (or Q1 2026 for quarterly taxpayers).”

6. Invoice Correction Rules:

  • Elimination of Correction Notes: From February 1, 2026, correction notes will no longer be valid. Instead, only corrective invoices issued by the seller will be allowed. “Starting February 1, 2026, the issuance of correction notes will be prohibited, requiring taxpayers to adapt their processes.”
  • Incorrect NIP Correction: The most common error (incorrect buyer NIP) requires a two-step procedure involving a zeroing correction invoice. “The most common error—incorrect buyer NIP—cannot be simply corrected; instead, a two-step procedure involving a zeroing correction invoice is required.”
  • Limited Scope of Corrections: The rules for issuing corrective invoices in KSeF do not change; it is not required to state the amounts before and after correction, except for advance invoice corrections. “The rules for issuing corrective invoices in KSeF do not change; it is not required to state the amounts before and after correction, except for advance invoice corrections.”

7. Practical Considerations and Challenges for Businesses:

  • “Disappearing Invoices”: There are reports of “disappearing invoices” in KSeF, where sellers receive confirmation, but buyers cannot see them. “Increasing reports of “disappearing invoices” in the National e-Invoice System (KSeF): sellers receive official confirmation, but buyers cannot see the invoices.”
  • Accountant Time Pressure: Implementation of KSeF will likely speed up VAT refunds, but also increase time pressure and responsibility on accountants. “Implementation of KSeF will speed up VAT refunds for companies…Accountants will face increased time pressure and responsibility.”
  • Invoice Visualization: If an invoice does not yet have a KSeF number and the buyer is not a consumer or a foreign entity, a transaction confirmation with two QR codes must be issued.
  • Data Validation: Careful data validation, especially of NIP numbers, is critically important before issuing invoices. “The KSeF system’s unchangeable transaction register makes data validation, especially of NIP numbers, critically important before issuing invoices.”
  • Need for Internal Archiving: While KSeF will archive invoices for 10 years, maintaining an internal archive is still recommended for practical and security reasons. “Maintaining an internal invoice archive is still recommended for practical and security reasons.”
  • Need for Company-Specific Procedures: Implementing a company-specific KSeF procedure is not mandatory but highly useful for documenting sales, purchase invoices, and handling KSeF outages.
  • Software Provider Changes: Companies should document current configurations, identify critical reporting deadlines, and plan for a smooth migration and team training to ensure a smooth transition to a new provider, should the need arise.
  • Training: The Ministry of Development and Technology is holding a free webinar to address any questions about KSeF, including implementation deadlines, common user mistakes, support tools, and practical preparations.
  • Address Updates: The Ministry of Finance is updating the service addresses for KSeF, and old addresses will be completely disabled on January 17, 2026.
  • Phantom Invoices: Uploading invoices to KSeF after they have been sent to clients may result in “phantom invoices,” creating confusion over which document is the official VAT invoice.
  • Non-Transactional Movement: Moving one’s own goods from Poland to a warehouse in another EU country will require issuing a structured invoice.
  • Fraud: The Ministry of Finance is introducing a mechanism in KSeF to protect against invoice fraud, allowing buyers to report suspected scam invoices. Buyers must validate with official KSeF portals, and not simply scan QR codes.
  • Contractor Agreements: Before February 1, 2026, businesses must agree with their contractors on how invoices issued in KSeF will be made available.

8. Authentication and Permissions:

  • Authentication Methods: Entities using the National e-Invoice System require the use of an electronic identification medium, data verified using a qualified electronic signature, data verified using a qualified electronic seal, or a KSeF certificate.
  • Entitlements: Permissions in the system can be delegated at the entity level, rather than requiring each individual employee to have permissions assigned.

9. Penalties and VAT refunds:

  • KSeF is expected to speed up VAT refunds, reducing the waiting period from 60 to 40 days.
  • In the first year of mandatory KSeF, businesses will not be penalized for errors like issuing invoices outside the system, but VAT sanctions for incorrect settlements will still apply after February 1, 2026.
  • KSeF-specific penalties (up to 100% of VAT on invoices outside KSeF) will only apply from January 1, 2027.
  • VAT refunds may be delayed if invoices are entered late into KSeF, as the right to deduct VAT arises only when the invoice is submitted to the system.

Sources

Briefing document & Podcast: Poland E-Invoicing, E-Reporting and KSeF Mandate – VATupdate

 

 

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