Electronic Invoicing in Poland
Is e-invoicing mandatory in Poland ?
Important note: In a press briefing held on January 19, 2024, Minister of Finance, Andrzej Domański, announced the postponement of the mandated KSeF implementation for 2024. This delay is attributed to critical errors discovered during preliminary analyses, encompassing code, functionality, and system performance issues.
An external Audit of the KSeF has been conducted and on 26th April 2024 the Ministry of Finance announced that due to critical errors found, it has been decided to build the system architecture from scratch. As a consequence, there will be a new schedule for the implementation of the mandate, as follows:
- As of 1st February 2026: This deadline applies to taxpayers whose turnover exceeded PLN 200 million (~EUR 46 million) in the preceding year.
- As of 1st April 2026: All other taxpayers must adhere to this implementation deadline.
On the 5th of June 2024, the President of Poland signed the act delaying the mandatory implementation of the National e-Invoicing System (KSeF) according to the mentioned timelines.
Please note that Poland began a pilot program in 2021 to implement an e-invoicing clearance model called Krajowego Systemu e-faktur (KSeF), a system for which technical details were released in August 2021.
In October 2021, the KSeF Pilot project began allowing service providers and taxpayers to test the platform. As of January 2022, taxpayers can voluntarily use the platform in parallel with paper and PDF invoices.
Basware is closely following all the regulatory changes in Poland, so we can offer you innovative products that meet the requirements of the forthcoming e-invoicing mandate.
Regarding B2G, in November 2018, Poland adopted the 2014/55/EU Directive regarding electronic invoicing for public procurement.
In force since April 2019 for central and sub-central public entities, Poland built its own public invoicing portal for the Business-to-Government (B2G) sector. The Platformy Elektronicznego Fakturowania (PeF) facilitates the transmission of e-invoices between private companies and public bodies.
Poland uses the standard e-invoicing format based on EN 16931 and Peppol BIS Billing supported by Basware.
New JPK CIT Regulation
On the website of the Government Legislative Center (Polish:RCL) the Ministry of Finance published information on the submission for urgent publication in the Polish Journal of Laws of the regulation regarding additional data that should be included in the so-called JPK-CIT (SAF-T for corporate income tax purposes).
The regulations imposing obligations concerning JPK-CIT, including this regulation, come into effect on January 1, 2025. There is not much time left, and there are many tasks to be completed. The regulation is awaiting publication.
Regulation submitted for publication differs from previous drafts as it incorporates amendment proposals made by the Legal Committee. The previous version excluded the requirement to submit data from the fixed assets register in the first year starting after December 31, 2024 (which was interpreted as a lack of obligation to submit JPK_ST_KR). However, the final version no longer includes such a provision. The wording of the remaining exemption refers to additional data, not to the register itself. Therefore, the final content of the regulation indicates the obligation to send JPK_ST_KR also in the first year for which JPK-CIT will be submitted. Additional explanations regarding this matter may be included in the informational brochure for the new JPK structures, which should be published soon by the Ministry of Finance.
Regardless of the changes in the regulation itself, the first taxpayers will submit JPK-CIT for the fiscal year beginning after December 31, 2024. This applies to entities with tax revenues exceeding EUR 50 million and tax capital groups. In practice, JPK-CIT comprises two structures:
- JPK_KR_PD (primarily covering the trial balance, records on accounts, and so-called tax markers indicating how the operations have been recognized for CIT purposes), and
- JPK_ST_KR (registry of fixed assets and intangible assets, containing specified data – this is the structure referred to in the earlier mentioned uncertainty).
Poland - KSeF – the new logical structure of the e-invoice FA(3) will be made available for public consultation in autumn 2024
Important updates in the National e-Invoicing System (KSeF)! The new logical structure of the FA(3) e-invoice will be made available for public consultation in autumn 2024.
Due to the high load on the test environment of the National e-Invoice System (KSeF), the Polish Ministry of Finance has introduced restrictions on the acceptance of test invoices. They concern:
- limiting the size of the query sent to 10 MB;
- limiting the number of queries sent to 100/min. In the event of a violation of this restriction, the user's IP is temporarily blocked, then with a progression from 1 min to 10 minutes, then every 10 minutes.
Due to the great interest in the KSeF test environment and its specificity, the changes introduced are intended to provide all users with the ability to conduct tests in a stable environment.
See also full press release on website Polish Ministry of Finance ->
On 5 November 2024, on the Government Legislative Centre website, the draft act amending the VAT Act was published, which contains a proposal for changes in the scope of mandatory issuing of invoices in the National e-Invoice System (KSeF) in Poland, hereinafter referred to as: "e-invoices".The changes introduced in the KSeF system by this draft act are intended to make it easier for companies to adapt into the new invoicing model:
- Introduction of mandatory KSeF for all taxpayers (for active taxpayers and taxpayers exempt from VAT), taking into account the phasing:
- from 1 February 2026 for entrepreneurs whose sales value (including the amount of tax) exceeded PLN 200 million in 2025,
- from 1 April 2026 for other entrepreneurs.
- Simplifications and postponements of:
- the possibility of issuing invoices at cash registers until 31 July 2026,
- o the requirement to provide the KSeF number in payments for e-invoices, including those invoices made using the split payment mechanism until 31 July 2026
- introduction of voluntary "offline mode" by the end of 2026 ,
- six-month transitional period (until 30 September 2026) for micro-entrepreneurs who issue invoices worth up to PLN 450 and monthly sales of up to PLN 10,000.
- New functionalities:
- the possibility of issuing e-invoices voluntarily for consumers,
- introduction of the functionality of sending invoices with attachments (e.g. for media, telecommunications),
- the ability to install certificates for QR codes no earlier than November 1, 2025,
- replacement of the optional system with a mandatory one in Q4 2025 (with the possibility of testing new functionalities).
- Other changes:
- the requirement to provide the Tax Identification Number of the unit subordinate to the local government unit on the invoice - for this purpose, a change to the e-invoice scheme will be proposed,
- o extending access to data in the KSeF so that the National Revenue Administration ("KAS") bodies can use this data to perform their statutory tasks.
More details can be found on the Government Legislative Centre website, under the following link ->
On 6 November, on the website of the Polish Ministry of Finance, a notice regarding the commencement of tax consultations on the logical structures FA(3) and FA_RR(1) and the concept of functioning of the invoice attachment in KSeF was published. The structures made available are the result of consultations with entrepreneurs.
The consultation will last until 22 November 2024.
More information can be found at the Ministry of Finance website by the link ->
Want to learn more about e-Invoicing compliance?
Download our Global e-invoicing and Tax Compliance fact sheet here for more information.
Archiving
The KSeF platform of the new mandate offers a basic built-in archive that will store invoices for 10 years, relieving businesses from the requirement to store the documents electronically separately, however Basware offers Vault solution in Poland guaranteeing integral, independent, and reliable e archiving.
The retention period of invoices is 5 years after the end of the fiscal year.
Want to know more about Basware’s archiving services?
Download our Basware Vault fact sheet here to learn more about our flexible and scalable solution.
Basware Services
Basware continues to keep up to date with the latest changes in Poland and it is committed to providing grounded e-invoicing solutions according to the polish regulations and KSeF requirements.
Want to find out how we can help in your specific case?
Speak to a member of our team to learn more.
Interoperability
At Basware, we are passionate about delivering the benefits of open interoperability to our customers. So, we have partnered with more than 220 e-invoicing networks around the world to ensure the Basware Network remains the largest open commerce network of buyers and suppliers.
Our advice
Poland is following the trend of Italy, Spain, and France in adopting a clearance model.
The country will require taxpayers to use the KSeF platform from February 2026 for B2B e-invoicing. This platform is technical and has no capability of uploading PDFs or a portal to upload data.
Basware advises customers to automate their invoice receiving and sending process by connecting to the governmental platform through the Basware Network.
What changes to expect from the new JPK CIT Regulation
Here's what you need to know:
- The Ministry of Finance indicated that due to numerous business demands submitted during public consultations held in February and March 2024.
- A decision was made to modify the FA(2) structure. It will therefore be necessary to adapt programs to new version of the FA structure (3).
- New version of FA(3) structure will be made available for public consultation in autumn 2024. The changes are intended to be beneficial for taxpayers, including: presentation of the payment deadline, the new role of "employee" in the Entity3 element, increasing the number of characters in the P_7 field (name of the product or service) and solutions dedicated to local government units and VAT groups.
- The Ministry of Finance indicated that work on the second stage of legislation is currently underway. After its completion, legislative work on implementing acts will be resumed.
- At the same time, regulation of the Minister of Finance of December 27, 2021 regarding the use of the National e-Invoice System will be repealed (Journal of Laws of 2021, item 2481, as amended). The Ministry of Finance will publish new regulations, the provisions of which will partly overlap with the current wording, and partly will cover new provisions dedicated to the mandatory version of the system (QR codes, two-stage access to invoices, internal certificates).
- Based on the results of the IT audit, the Ministry of Finance decided to initiate construction of a new KSeF architecture from the beginning however this change shall not significantly impact integrators and works already performed within the area of integration with KSeF.
- The Ministry of Finance indicated that there are no plans to abolish the obligation to provide the KSeF number when making payments for a structured invoice. However, this obligation will only apply to payments made starting from August 1, 2026.
- At the same time, the Ministry of Finance indicated that there are certain activities planned: the so-called alignment of environments (test, pre-production and production) to enable a stable integration process with KSeF; implementation of invoice attachments, updating the FA structure.
The full text of the answers to questions about KSeF is available on the government website here ->
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