Proposed regulation under Article 106r of the Polish VAT Act concerning the National e-Invoicing System (KSeF):
Summary of the Draft Regulation on KSeF (as of 1 September 2025)
Purpose
The regulation fulfills the delegation under Article 106r of the VAT Act and sets out detailed rules for the use and technical handling of Poland’s National e-Invoicing System (KSeF).
Key Provisions
- Authorisations: Defines types of authorisations for using KSeF, how they are granted or withdrawn, and the notification templates for these actions.
- Authentication: Specifies how entities accessing KSeF must authenticate themselves.
- Anonymous Access: Outlines the scope of data available for anonymous access to invoices, including VAT RR invoices.
- Invoice Marking:
- Details how invoices (structured, offline, or issued during system failure) must be marked after submission to KSeF.
- Covers invoices made available outside KSeF (e.g. to non-domestic VAT payers) and the technical requirements for ensuring authenticity and data integrity.
- Special Invoice Types:
- Includes rules for VAT RR and VAT RR CORRECTION invoices used outside KSeF.
- Specifies how invoices under Articles 106nda(1), 106nf(1), and 106nh(1) must be marked and verified.
- Attachments to Invoices:
- Defines the data scope and procedures for issuing invoices with attachments.
- Includes compliance declarations, awareness statements, and procedures for starting or stopping the use of attachments.
- Sets technical standards for sending invoices with attachments to KSeF.
Implementation Timeline
| Provision | Effective Date |
|---|---|
| General Regulation | 1 February 2026 |
| § 6(1)(1) (postponed provision) | 1 April 2026 |
| §§ 10–12 | 1 January 2026 |
Sources
- 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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