The Polish Ministry of Finance has recently published a new draft of legislation regarding the National e-Invoicing System (KSeF). This update brings important changes to the implementation timeline and introduces several operational modifications that will affect businesses operating in Poland.

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Confirmed implementation timeline

The most significant announcement is the official confirmation of the mandatory KSeF implementation dates:

  • For businesses with annual sales exceeding 200 million PLN in 2024: February 1, 2026
  • For all other businesses: April 1, 2026

Development and regulatory roadmap

The Ministry of Finance has outlined a clear timeline for the KSeF implementation process. The final legislation is expected to be published by July 2025. Prior to this, in June 2025, the new FA(3) schema and KSeF 2.0 API documentation will be made available to developers and businesses. Starting from September 30, 2025, companies will have access to the KSeF 2.0 testing environment to prepare and adjust their systems. The full production version is scheduled to launch on February 1, 2026, coinciding with the mandatory implementation date for larger businesses.

Compliance grace period

The Ministry has postponed certain enforcement measures until January 1, 2027, including:

  • Penalties for non-compliance with KSeF requirements
  • The requirement to include KSeF invoice numbers in payment transfer descriptions

New operational features

  • Offline e-Invoicing: Businesses will be able to issue electronic invoices "offline" (outside the KSeF system) with QR codes, requiring submission to KSeF no later than the next business day
  • Invoice Attachments: Confirmation of the ability to include attachments with KSeF invoices, subject to specific conditions
  • Standardized QR Codes: Introduction of standardized QR code formats for both online and offline invoicing modes

Business process implications

These changes will have significant implications for purchase and sales processes across Polish businesses. The offline e-invoicing option with QR codes, in particular, offers more flexibility but requires companies to adjust their systems accordingly.

Organizations should start preparing their IT infrastructure and internal processes well in advance of the implementation deadlines to ensure a smooth transition to the new system.

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