- Go-Live Dates and Predictability: The mandatory implementation dates for KSeF remain unchanged, with 1 February 2026 for taxpayers with sales over PLN 200 million and 1 April 2026 for all other entities. The reference year for the PLN 200 million threshold will now be based on 2024 sales, improving predictability for taxpayers.
- Transitional Periods and Micro-Business Exemptions: Key transitional periods have been extended until 31 December 2026, allowing more time for compliance. However, the criteria for micro-business exemptions remain unchanged, which may pose practical challenges for businesses that do not fit neatly within the existing thresholds.
- Offline Mode and Payment Requirements: A permanent Offline24 mode has been introduced for issuing invoices outside KSeF, but the deadline for submission remains the next business day. The requirement to include the KSeF number in B2B payment references is postponed to 1 January 2027, raising ongoing concerns about system adjustments and practical implications for businesses
Source: mddp.pl
Slides from a presentation of the Ministry of Finance
Proposal from the Polish Ministry of Finance regarding changes to the Krajowy System e-Faktur (KSeF), which is Poland’s national e-invoicing system. The document outlines various proposed changes and timelines for implementing KSeF 2.0, including adjustments to mandatory usage dates, offline invoicing options, and the addition of attachments to invoices.
Key points include:
- Implementation Timeline: The document specifies key dates for the rollout of KSeF 2.0, including legislative completion, API documentation publication, and testing phases.
- Mandatory Usage Dates: The proposal suggests maintaining the original dates for mandatory KSeF usage but recommends analyzing sales data from 2024 instead of 2025 to determine applicability.
- Offline Invoicing: Introduction of an “offline” mode for issuing invoices with QR codes, allowing for flexibility in case of system outages or specific transaction needs.
- Attachments to Invoices: Proposal to allow attachments for invoices related to media, telecommunications, and other bulk services, addressing the need for detailed data inclusion.
- Certification and Testing: Plans to enable early generation of invoice issuer certificates and provide a test environment for KSeF 2.0 to facilitate integration and preparation.
- QR Code Standardization: Unification of QR code elements for online and offline modes to ensure data integrity and security.
Other Newsletters on this topic
- Mandatory KSeF Implementation Dates: The bill confirms the mandatory implementation of KSeF, set for 1 February 2026 for taxpayers with sales exceeding PLN 200 million and 1 April 2026 for all other taxpayers. The “offline24” mode will allow invoices to be issued outside KSeF, but they must be submitted by the next business day.
- Attachments and Consumer Invoicing: The draft allows structured invoices to include attachments, provided they meet specific conditions. Invoicing for consumers (B2C) remains optional, and structured invoices do not require consumer consent. However, invoices for non-VAT registered consumers must still include a QR code.
- Transition Periods and Sanctions: Key transitional measures have been extended until the end of 2026, allowing micro-entrepreneurs to issue certain invoices outside KSeF. Penalties for non-compliance will be postponed until 1 January 2027, giving businesses more time to adjust to the new regulations. Additionally, the Ministry of Finance plans to release the KSeF 2.0 specifications and provide testing environments starting November 2025.
Source Deloitte
- Confirmed Implementation Dates: The Polish Ministry of Finance has confirmed that the KSeF e-invoicing mandate will commence on 1 February 2026 for large taxpayers and on 1 April 2026 for all other taxpayers, with a grace period for penalties until the end of 2026.
- KSeF 2.0 Rollout Timeline: Key milestones for the KSeF 2.0 implementation include the publication of documentation in June 2025, API testing available by 30 September 2025, and the release of a test version of the KSeF 2.0 Taxpayer Application in November 2025.
- Expanded Features and Flexibility: The updated KSeF will introduce options such as the “offline24 mode” for invoice issuance, the ability to submit attachments to invoices, and the optional issuance of B2C invoices. Additionally, the requirement for including the KSeF number in payments has been postponed until 1 August 2026, allowing businesses time to adapt to the new system.
Source Edicom
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