On Thursday, 18 July, the Ministry of Finance hosted another consultation meeting on the National System of e-Invoices (KSeF), which we had the opportunity to attend. Below are the most significant findings and changes that were discussed during the meeting. 

Key information from the meeting

1. Deadline for KSeF implementation

The effective dates for the KSeF obligation of 1 February and 1 April 2026 have been confirmed, which is good news for businesses who can now plan their preparations for the new system with greater confidence. 

2. Change of e-invoice schema

Contrary to earlier assurances, the FA(2) e-invoice schema will change. A draft of the new FA(3) schema is expected to be published in September. This unexpected change may require businesses to incur additional costs to adapt their systems. 

3. Introduction of structured attachments to e-invoices

It is proposed to introduce structured attachments to e-invoices on a voluntary basis. This solution aims to 

  • Include complex details required by regulation 
  • Include business-relevant details, even if not required by law 
  • Correct attachments 

A consultation on attachments is due to start in September and we should know the details by then. 

4. Offline mode

It has been confirmed that the possibility of using an offline mode, allowing e-invoices to be issued outside the KSeF and uploaded to the system the next working day, will be maintained. This solution will be 

  • Voluntary and temporary from 1 February 2026 
  • Likely to be available for a transitional period of six months only 

5. ‘Self-identification’ of taxpayers

The proposal to 'self-identify' the purchaser for income tax purposes has been withdrawn. The Ministry of Finance emphasises that the overriding aim is to 'simplify KSeF obligations'. 

6. Paper invoices for the smallest taxpayers

During the transition period, the possibility to issue paper invoices will be maintained, but only for the smallest taxpayers. The limits are to be PLN 450 (ca. €100) per invoice and PLN 10 000 (ca. €2350) per month. 

7. Alignment of test and production environments

Work has been announced to align the test and production environments to facilitate the testing of new developments. A roadmap of these changes is due to be published in September. 

8. New legislation

A draft of the new legislation (including the changes described above) is expected to be published at the end of September. A public consultation will also be launched at that time and is expected to last for about a month. 

Summary

The July KSeF consultation has produced a wealth of important information and changes. Although some areas still require clarification, the nature of the changes under consideration are not so revolutionary as to warrant a complete halt to preparations for implementation. 

It should be emphasised that there are many elements that companies can and should be working on now. This is particularly true for those aspects of the KSeF where there is no discussion and no significant changes are expected. A proactive approach to preparation can significantly facilitate the subsequent implementation of the system and minimise the risk of delays. 

We therefore encourage you to start or continue your preparatory work while monitoring the situation. It is worth keeping an eye on the KSeF's official website, where answers to questions are expected to be published after the meeting under an expanded 'Questions and Answers' tab. 

At CRIDO, we will continue to monitor these developments and stand ready to assist you in your KSeF preparation process. Our expertise allows us to identify those areas that can be optimised now, as well as those that may require a flexible approach as new information becomes available. 

Remember, despite some ambiguity, the general direction of change is known. Preparations made now will certainly pay dividends in the future, allowing for a smoother and less stressful transition to the new system when it becomes mandatory.