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New timetable for the Polish e-invoicing mandate

On April 26, 2024, after months of uncertainty over the schedule for Poland’s e-invoicing mandate coming into force, the country’s Ministry of Finance set out the long-awaited new timetable.

Polish e-invoicing obligations depend on the sale value realised by the company

The requirement for electronic invoicing in Poland will primarily be fulfilled through a national portal known as KSeF (Krajowy System e-Faktur).

Poland intends to implement its e-invoicing mandate in two distinct phases, based on the revenue generated by the organisation:

  • February 1, 2026, for companies whose sales value (including the amount of tax) exceeded PLN 200 million in 2025
  • April 1, 2026, for all other companies

Several anomalies and irregularities

After delaying the launch several times (the last one was planned for July 2024), we believe the latest postponement of more than 18 months is to allow time to fix anomalies identified during an external audit of the KSeF portal.

The Ministry of Finance indicated that the external audit revealed a number of irregularities, in particular, poorly designed IT architecture, which affected the efficiency, failure rate, security, maintainability, and further development of the system, and the possibility of its reproduction. The audit also revealed numerous errors and omissions regarding the project management.

Next steps

We expect the Ministry of Finance to publish the regulation reflecting the new timeline and any other regulation that could be affected such as the penalties.

In addition, Poland needs to make a new request for authorisation provided for in Article 395 (1) of Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax.

Avalara can help businesses prepare for the coming mandate in Poland. Contact us to learn more.

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