Poland introduces a new mandatory e-invoicing system in 2026

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Poland introduces a new mandatory e-invoicing system in 2026

November 15, 2025

Author:
Marcin Kaczanowicz
Doradca Podatkowy / Tax Advisor
INDEPENDENT TAX ADVISERS
Doradztwo Podatkowe Sp. z o.o.
E: [email protected]

Edited by:
Integra International
Grant Gilmour, B.Sc., MBA, CA, CPA Canada, BC, CPA USA, Az, GDipICL.Sc.
INTEGRA TAX WORLD NEWSLETTER EDITOR
E: [email protected]

Poland introduces a new mandatory e-invoicing system in 2026

Poland is going to introduce a new, mandatory e-invoicing system (called: KSeF). Application will be obligatory for most VAT taxpayers in 2026. The purpose of KSeF is digitalization of invoicing and improvement of accounting processes. Thanks to KSeF, the tax authorities will be able to fight VAT frauds more effectively as they will verify taxpayers’ VAT settlements on an ongoing basis. KSeF is also designed to prevent errors in invoicing.

It is worth noting that KSeF system being introduced in Poland is, in terms of its technical aspects and mode of operation, an original solution developed by Polish tax authorities. It is in no way related to, based on, or connected with other e-invoicing systems introduced in other EU countries. Therefore, when preparing for implementation of KSeF, it should be treated as a completely separate system, specific only to Poland.

According to the basic principle of the new system, VAT taxpayers will be required to issue the invoices in accordance with a single, top-down invoice template and send them in XML format to a central database maintained by the Polish tax authorities. The invoices will have to be sent immediately upon issuance or no later than the next working day as a rule. KSeF system will not verify the substantive correctness of the invoice, but only its compliance with technical requirements. After the invoice will be sent to KSeF and verified by the system, it will be assigned a KSeF number and automatically made available in the customer’s KSeF account, from where the customer will be able to download it. According to the Ministry of Finance, the entire process of sending, verifying, and making the invoice available to the customer will take only a few seconds. Therefore, it will not be necessary to send invoices to the customer in the current form, e.g. as a PDF file attached to an email. In addition, the system is to store all invoices sent to the system for a period of 10 years from the end of the year in which they were issued. Therefore, as a rule, the taxpayers will not be required to archive invoices sent via KSeF themselves, unless the obligation to store them for a longer period of time results from separate regulations.

The obligation to issue invoices via KSeF will be introduced in three stages:

  1. As of 1st February 2026 – it will apply to the taxpayers whose gross sales in 2024 exceeded PLN 200,000,000.
  2. As of 1st April 2026 – the obligation will be extended to the other VAT taxpayers, except for the smallest taxpayers whose gross sales do not exceed PLN 10,000 per month.
  3. As of 1st January 2027 – the smallest taxpayers will also be required to use KSeF.

As regards to receipt of invoices; all invoices issued via KSeF after 1st February 2026 to a Polish VAT taxpayer will be considered as delivered. This means that from 1st February 2026, all Polish VAT taxpayers will have to check whether they have received invoices in KSeF, even if they are not yet required to issue invoices in KSeF themselves.

There are several exceptions to the obligation to issue and receive invoices in KSeF. One of them allows an exception to  foreign entities, even those registered for VAT in Poland, provided that they do not have a permanent establishment in Poland or that permanent establishment does not participate in the supply of goods or services for which the invoice was issued. As a rule, these entities will issue and receive invoices to/from Polish taxpayers under the existing rules, unless, being registered for VAT in Poland when they voluntarily decide to use KSeF.

The obligation to issue invoices via KSeF will also not apply to invoices issued to consumers (B2C), but the taxpayers may voluntarily issue such invoices in KSeF.

Introduction of KSeF system means that Polish taxpayers will have to take several steps to adapt to the changes.

Firstly, ERP systems will require adoption to the invoice template itself. The invoice structure published by the Ministry of Finance includes several hundred fields, most of which are not mandatory. Nevertheless, the data that taxpayers have previously shown on their invoices must be mapped to the relevant fields of KSeF invoice structure, so that the system can correctly generate an XML file in the format required by the Ministry of Finance.

In addition, the introduction of the mandatory KSeF may also force several other changes, including in the following:

  1. Issuing and sending invoices to KSeF system – the invoices should be sent on an ongoing basis or at the latest on the next working day. In the event of any technical maintenance and unavailability of KSeF, the deadline for sending the invoice will be one working day from the date of the end of KSeF unavailability. In the event of KSeF failure, the deadline for sending the invoice will be seven working days from the date of the failure removal. Until 31st December 2026, late submission of invoices will not be penalized. However, from 1st January 2027, late submission of invoices will be subject to penalties of up to 100% of the VAT amount shown on the invoice.
  2. Sending invoices to customers – the customers using KSeF system will generally not need to receive the invoices from the supplier through a separate channel (e.g. by e-mail), although the regulations will not prohibit this. On the other hand, all entities not using KSeF will have to be provide with the invoices in a manner agreed with them (e.g. B2C sales, invoices for intra-Community supply of goods or export). In each case of using the invoice outside KSeF, i.e., when printing the invoice or sending it by email, the customer should receive from the seller a visualization of KSeF invoice with the appropriate QR code enabling verification of the invoice in KSeF. The requirement to attach QR codes to documents is an additional step that does not exist nowadays.
  3. Sending attachments – as a rule, except strictly defined cases, the invoices sent to KSeF will not have attachments. They will be XML files to which it will not be possible to attach, for example, a PDF file. The supplier will therefore have to decide whether to send attachments, e.g. by e-mail, or to include a link in the invoice to an attachment stored separately in the cloud so that the buyer can download it.
  4. Including additional information on the invoices, e.g. regarding the branch or person responsible for a given project on the buyer’s side. After changes, the customer will receive invoices directly from KSeF, not e.g. by e-mail (unless they agree with the supplier that a visualization of the invoice from KSeF will also be sent by e-mail). Without this type of information, the customer will have problems assigning the invoice to a given ‘cost centre’ and posting it.
  5. Self-billing – to enable the customer to issue invoices in KSeF on behalf of the supplier, the supplier will have to grant the customer special authorizations. In some cases, it will not be possible to issue the self-billing invoices in KSeF (e.g. when the customer or the supplier does not have a Polish tax identification number), although in some cases the system provides for exceptions.
  6. Collective corrections – until now, in the case of collective corrections concerning several hundred or several thousand original invoices, the data of the original invoices was often indicated in an attachment to the invoice. The new version of the invoice structure requires the data of all original invoices to be provided directly in the content of the corrective invoice. The taxpayers’ accounting system must be prepared for this.
  7. Corrections to documents by replacing the original document – although not in all cases in line with Polish VAT Law but in practice as difficult to detect have been not questioned by the tax authorities. Introduction of KSeF will make impossible to make corrections in this way, as all invoices will be visible in the system. As a result, the authorities will clearly see that an invoice has been issued twice, which will result in appropriate penalties.
  8. Including relevant data in the payment transfer orders – from 1st January 2027, the title of the bank transfer between two VAT taxpayers will have to include the number assigned to the invoice in KSeF or the collective identifier assigned by KSeF to more than one invoice (in the case of collective payments). If the taxpayers do not want to enter this type of data manually, their accounting systems must be adapted to retrieve this data from KSeF.

In addition, the implementation of KSeF also forces taxpayers to make a number of changes in the way their companies operate, and documents are circulated. The following should be determined:

  1. The persons responsible for sending or receiving invoices from KSeF, granting them appropriate authorizations in the system, downloading the relevant certificates enabling them to log into KSeF, and then ensure the security of these certificates and cancelling authorizations if a person leaves the company.
  2. The persons responsible for sending or receiving invoices from KSeF, granting them appropriate authorizations in the system, downloading the relevant certificates enabling them to log into KSeF, and then ensure the security of these certificates and cancelling authorizations if a person leaves the company.
  3. Methods for assigning purchase invoices to specific cost centres.
  4. Ways to avoid accidental double entry of invoices or their omission.

In practice, the process of implementing KSeF in a Company depends largely on the IT solutions the taxpayer has used so far and the scale of its operations. For the large taxpayers using tailor-made solutions entire process may take several months. Such implementation requires:

  1. verifying the data available in the company’s ERP systems,
  2. a thorough analysis of various types of documents, explanations and examples of XML files published by the Ministry of Finance in order to determine how the data available in the company’s ERP systems should be presented in the XML file sent to KSeF,
  3. organizing a series of internal meetings to discuss possible solutions,
  4. implementing changes, which usually involve not only software or accounting modules, but also related applications,
  5. training employees in new procedures.

In summary, the implementation of the new mandatory e-invoicing system in Poland is a serious challenge for the taxpayers and its IT, accounting, and tax teams. Each of these entities must be prepared for the changes that the new system will bring. Nevertheless, the correct implementation of this system gives hope:

  • on the one hand, to speed up invoicing and invoice accounting processes and reduce the number of human errors in the company,
  • on the other hand, to reduce the number of audits conducted by tax authorities (based on data from KSeF, the analytical systems of tax authorities should be better at identifying suspicious transactions or entities).

As a result, it should be expected that the introduction of KSeF, despite initial difficulties, should bring positive effects for VAT taxpayers in the long term.

Disclaimer

This communication contains general information only based on collective research. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No representations, warranties or undertakings (express or implied) are given as to the accuracy or completeness of the information in this communication, and none of INDEPENDENT TAX ADVISERS Doradztwo Podatkowe Sp. z o.o., Integra International, related entities, employees or agents shall be liable or responsible for any loss or damage whatsoever arising directly or indirectly in connection with any person relying on this communication.

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About the Author:

Marcin Kaczanowicz

Marcin is a graduate of Warsaw School of Economics and licensed tax advisor for over 12 years. He  specializes in VAT and INTRASTAT issues and has extensive practical knowledge in such fields as: VAT and INTRASTAT registration procedures, preparing applications for VAT refunds, preparing VAT and INTRASTAT returns. He is also actively involved in all kinds of issues connected with our client’s tax settlements in Poland, tax reviews, tax controls, etc. He is responsible in our Company for day-to-day support for foreign Clients active in the fields of electronics, household appliances, production of machinery and conducting distance sales in Poland.

About Independent Tax Advisers Doradztwo Podatkowe Sp. z o.o.:

Our firm has been operating in the market since February 2004. ITA Doradztwo Podatkowe offers an individual approach to tax aspects of each of its Clients. We concentrate on dynamic growth of our firm and on ensuring the highest quality of services guaranteed by a fully independent tax advisory firm.

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