The Ministry of Finance has unveiled an updated timetable and package of solutions to support the implementation of the National e-Invoicing System (KSeF). After numerous consultations with entrepreneurs and technical analysis of the system, the Ministry has confirmed a new two-stage plan for the mandatory introduction of e-invoices.
New KSeF implementation plan – stages
- 1 February 2026 – compulsory invoicing in KSeF for large taxpayers whose gross sales value in 2024 will exceed PLN 200 million,
- 1 April 2026 – obligation for other entrepreneurs, except for the smallest so-called ‘digitally excluded’ taxpayers (invoices up to PLN 450 and sales up to PLN 10,000 per month),
- 1 January 2027 – obligation for the smallest ‘digitally excluded’ taxpayers.
RR VAT invoices will not be compulsory in KSeF, although the possibility to issue them voluntarily will appear from 1 April 2026.
Facilities for taxpayers
The Ministry has announced a number of solutions to support taxpayers in the transition to KSeF by the end of 2026:
- No penalties for invoice errors introduced by KSeF,
- No obligation to include the KSeF number in transfers – also with the split payment mechanism (MPP),
- Retention of the possibility of issuing invoices from cash registers,
- ‘Offline24’ mode – it will be possible to issue invoices outside the KSeF system (e.g. in the event of network problems), with subsequent uploading to the system
Key dates and technical activities
- June 2025 – publication of the FA(3) schema and KSeF 2.0 API documentation,
- 30 September 2025 – start of open testing of the KSeF 2.0 API for integrators and large companies,
- November 2025 – release of a test version of the KSeF 2.0 Taxpayer Application,
- 1 November 2025 – possibility to obtain an e-invoice issuer certificate (necessary for offline operation).
KSeF 2.0 mobile app
The Ministry of Finance will provide free access to the updated KSeF mobile app. It will enable:
- issue and send e-invoices,
- manage multiple vendor profiles,
- creation of a database of buyers and bank accounts,
- verification of the existence of an invoice in KSeF by the buyer.
Invoice attachments and mass invoices
In response to market demands, it will be possible to add attachments to KSeF invoices, the structure of which will be described in the FA(3) schema. In addition, the possibility for consumers to voluntarily issue e-invoices will also be retained, which will facilitate mass invoicing (e.g. by utility or subscription service providers).
Summary
The new timetable and the flexible approach of the Ministry of Finance is a response to the demands of the market and a real preparation of entrepreneurs for the transition to KSeF. Although the e-invoicing obligation has been postponed, it is worth starting preparations now – planning the integration of systems, carrying out training and following the MF’s publications on the schema and API.
Making business easier.
