PEPPOL IN EUROPE
E-invoicing in Poland
From January 1, 2022, the National e-Invoice System was introduced as a voluntary solution in Poland, making it possible to exchange structured invoices. During a press briefing on January 19, 2024, Poland’s Minister of Finance announced a postponement of the mandatory implementation of the National e-Invoice System (Krajowy System e-Faktur, KSeF).
According to the Minister’s statement, the obligation will come into force in February 2026 for large taxpayers (with sales value exceeding PLN 200 million in the previous tax year) and in April 2026 for the remaining taxpayers. It is also likely that taxpayers exempt from VAT will be affected by that obligation from 2026. B2C transactions are out of the scope of the mandate.
The Ministry of Finance presented new objectives regarding KSeF in the draft legislation with the following main points:
- June 2025: Publication of the FA(3) logical structure on ePUAP and release of the KSeF 2.0 API documentation.
- July 2025: Completion of the relevant legislation.
- September 1, 2025: Deactivation of some elements (in preparation for the new system).
- September 30, 2025: Launch of open tests for the KSeF 2.0 API.
- Mid -October 2025: The pre-production (demo) environment is opened for testing.
- November 2025: Issuance of invoice issuer certificates to entrepreneurs and provision of a test version of the KSeF 2.0 Taxpayer Application.
- February 2026: Implementation of Mandatory KSeF 2.0 - Stage I
- April 2026: Implementation of Mandatory KSeF 2.0 - Stage II
- January 2027: Obligation for “digitally excluded” taxpayers whose transactions involve small amounts (up to PLN 450 for a single invoice and a total sales value of up to PLN 10,000 per month) - Stage III
The Polish Ministry of Finance has released final versions of key technical components of the system. These include the target logical structure of the FA(3) e-invoice, the complete KSeF 2.0 API documentation, and extended support materials for system integrators and users.
The National e-Invoices System addresses all enterprises established and operating in Poland, including foreign entities conducting business there. Using KSeF will bring several benefits to taxpayers. It will facilitate the settlement of structured correcting invoices, eliminate the obligation to deliver invoices in the JPK (Jednolity Plik Kontrolny—Uniform Audit File) format, enable a faster refund of turnover tax, and ensure that invoices are archived in KSeF for ten years.
Effective January 1, 2026, Poland will raise its annual VAT registration threshold from PLN 200,000 to PLN 240,000 (approx. EUR 56,000). This adjustment, introduced as part of
E-invoicing for B2G has been in place in Poland since 2019. For the issuance of invoices to public authorities, a special e-invoicing platform was provided: the PEF portal (Platforma Elektronicznego Fakturowania). This portal was developed within the scope of implementing EU Directive 2014/55/EU. It enables suppliers to the public sector to submit their invoices electronically and obliges public entities to receive e-invoices via this platform if suppliers choose to do so. For this, PEPPOL BIS Billing 3.0, as well as UBL 2.1 and UN/CEFACT CII are to be used.
