Please note that on 11 April 2025, the Polish Ministry of Finance published a revised draft of the legislation introducing mandatory e-invoicing via the National e-Invoicing System (KSeF). The draft includes several important regulatory changes, however the planned implementation timeline is not changed – February/April 2026.

The draft has been made available for public consultation, and stakeholders may submit comments until 25 April 2025.

Below is a summary of the key changes:

Effective dates and threshold

  • Mandatory KSeF will apply from 1 February 2026 for taxpayers whose gross sales in 2024 exceed PLN 200 million,
  • For other taxpayers, the obligation will start from 1 April 2026.

Transitional period extended (until 31 December 2026):
The following obligations are postponed until the end of 2026:

  • Mandatory inclusion of the KSeF invoice number in payment transfer (including split payment transfers),
  • Application of penalties for non-compliance with KSeF obligations,
  • Discontinuation of invoice issuance via cash registers and simplified invoices based on NIP-labelled receipts,
  • Temporary exemptions for digitally excluded micro-businesses (subject to conditions).

B2C Invoicing
The use of KSeF for transactions with consumers (B2C) will be optional. Invoices issued via KSeF must include a QR code and may be delivered to consumers by agreed means (e.g. email or printout).

Offline mode (Offline24)
The legislation introduces a permanent option to issue structured invoices outside the KSeF system (so-called Offline24) in predefined circumstances. Such invoices must be submitted to KSeF no later than the next business day. The issuance date indicated on the invoice will be treated as the official date of issuance. Also when a structured invoice is issued in the standard (online) mode but is submitted to KSeF later than the date of issue stated in the invoice, it is considered to be an “offline invoice”. This means that for this invoice the issuance date is always as stated on the invoice, not the date of submission to KSeF.

KSeF number in payments
The requirement to include the KSeF invoice number in B2B bank transfers will apply as of 1 January 2027.

Technical documentation and API

  • A new version of the invoice schema and updated API documentation is expected in June 2025,
  • The updated test API environment is scheduled for release by the end of September 2025.

Find out more during the upcoming webinar, which will be held in Polish: https://bpcc.org.pl/pl/events/obowiazkowy-ksef-w-2026-roku-co-zmienia-najnowszy-projekt-przepisow-mf/.

Should you wish to discuss the implications of the draft or require support in your KSeF implementation process, please do not hesitate to contact us.

Kind regards,

Janina Fornalik

Partner | Tax Adviser

E: janina.fornalik@mddp.pl

T: +48 660 440 141

Krzysztof Jaros

Manager | Attorney at Law

E: krzysztof.jaros@mddp.pl

T: +48 504 399 980

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