Polish e-invoicing mandate updates

The Polish government publishes documentation on an updated version of its national e-invoicing system Krajowy System e-Faktur (KSeF). KSeF 2.0 includes the FA(3) structured invoice schema, updated API documentation, and an integration testing schedule. 

The Polish Ministry of Finance releases new draft regulations on obligatory e-invoicing, confirming the phased implementation dates. From February 1, 2026, e-invoicing will be mandatory for large enterprises with annual sales exceeding PLN 200 million. From April 1, 2026, e-invoicing will be mandatory for all other businesses.

After months of uncertainty over the schedule for Poland’s e-invoicing mandate, the country’s Ministry of Finance sets out a new timetable. Poland intends to implement its e-invoicing mandate in two 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, and April 1, 2026, for all other companies. 

The President of Poland signs the Act of June 16, 2023, amending the VAT Act and other laws, confirming the introduction of mandatory e-invoicing via KSeF starting July 1, 2024.

The Polish Ministry of Finance confirms Poland’s e-invoicing mandate will not come into force on January 1, 2024, as planned. It is instead postponed by six months. The decision is based on public consultations and discussions with businesses. 

The European Commission issues a draft derogation decision for approval authorising Poland to implement mandatory e-invoicing. The Polish Ministry of Finance confirms that based on the derogation, Poland will move forward with implementing “universal electronic invoicing” in Poland.

Poland launches the national e-invoicing system KSeF for voluntary use, allowing businesses to issue structured e-invoices.

Poland submits a request to the European Commission for an exemption from the rule under the EU VAT Directive that stipulates the use of an e-invoice shall be subject to acceptance by the recipient. Within the EU, the decision to use e-invoices is a matter of agreement between the trading parties and is not mandated by a tax authority or forced upon a customer by its supplier. Member states wishing to remove the right of a recipient to receive an invoice in paper format must get approval from the European Commission.

The Polish government announces a public consultation on imposing mandatory business-to-business (B2B) e-invoicing by 2023, with a planned voluntary phase from October 2021. Poland intends to seek permission to deviate from the EU VAT Directive that requires taxpayers to issue paper-based invoices unless they receive written consent from recipients to issue e-invoices.

For more information on e-invoicing in Poland, check out:

• Poland’s new National System of e-Invoices (KSeF)
• Poland’s KSeF e-invoicing postponed by six months
• Green light for mandatory e-invoicing in Poland from 2023
• Four recent VAT and e-invoicing updates in Poland