Follow-Up: Poland’s KSeF Evolution – Challenges, Solutions, and Implementation Outlook

The Challenges: why change was needed

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The aim of the KSeF system is to streamline and harmonise invoicing in Poland, covering all activities requiring documentation under the VAT Act. However, the road to mandatory implementation has been fraught with technical and practical challenges, such as system efficiency concerns, legal complexity and transition barriers for small businesses.

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Early audits revealed that KSeF was not equipped to handle the expected volume of millions of invoices daily, leading to a risk of system failures. Businesses highlighted issues such as unclear rules for consumer invoices and difficulties for VAT-exempt businesses to comply. In addition, it was found that digitally excluded taxpayers and small-scale entrepreneurs faced significant challenges in adapting to e-invoicing.

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Stakeholder consultations: listening to businesses

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To address these challenges, the Ministry of Finance undertook extensive consultations with businesses between February and April 2024, involving more than 10,000 participants. These discussions revealed:

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• The need for an offline mode to allow businesses to issue invoices during system downtimes.
• Simplifications for issuing consumer invoices, especially where buyers do not have a VAT identification number.
• A transition period for small businesses to continue using traditional invoicing methods while they adapt to the new system.

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Based on the feedback, the Ministry prepared a draft act proposing key changes to the KSeF system.

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Key changes and phased implementation under discussion

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To ensure a smoother transition, the Ministry adopted a phased approach to mandatory e-invoicing, along with practical measures to address stakeholder concerns.

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The mandatory use of KSeF will now be introduced in phases:

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1 February 2026: For large businesses with an annual turnover exceeding PLN 200 million (~ EUR 46 million).

1 April 2026: For all remaining businesses, including VAT-exempt entities.

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Transitional measures

During the transitional period, taxpayers may issue invoices outside the KSeF system using an offline mode with QR codes. These invoices can be uploaded to the system on the next business day, ensuring compliance without real-time connectivity.

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Businesses can opt to include consumer invoices in the KSeF system, addressing concerns about identifying non-VAT registered buyers.

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Small businesses with low invoice volumes and small individual invoice amounts (≤PLN 450 per invoice and ≤PLN 10,000 monthly) can continue using traditional methods until 30 September 2026. This buffer period allows them to adapt gradually without disrupting day-to-day operations.

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Deferred deadlines

Certain requirements, such as providing the KSeF number in payment processing and phasing out cash register invoices, have been postponed until 31 July 2026.

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Test environment

A “playground environment” feature will allow businesses to test KSeF functionalities, including offline invoicing, in a simulated live environment. This initiative will ensure readiness before full implementation.

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Attachment functionality

In response to industry feedback, the Ministry of Finance is exploring the possibility of adding attachment functionality to structured invoices. While the specifics of this feature are still under discussion, this addition could provide businesses with greater flexibility in meeting invoicing requirements.

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Looking ahead

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Poland’s approach to mandatory e-invoicing reflects a commitment to balancing technological progress with practical business needs.

As we move closer to the 2026 deadlines, businesses are encouraged to:

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• Test and learn: Take advantage of the “playground environment” to familiarise themselves with KSeF functionalities.
• Upgrade systems: Work with service providers to ensure compatibility with KSeF requirements.
• Stay informed: Monitor updates from the Ministry of Finance and consult with tax experts.

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