Author:
Dorota Baczewska-Golińska, Licensed Tax Adviser
Independent Tax Advisers Doradztwo Podatkowe Sp. z.o.o., Partner
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]
E-invoicing in Poland in 2026
The Country System of e-Invoices (in Polish: Krajowy System e-Faktur/KSeF) became obligatory as of 1st February 2026 for the taxpayers whose total sales (with VAT) crossed in 2024 PLN 200 000 000 (approx. EUR 48 m). The other taxpayers will be obliged to issue Invoice via KSeF as of 1st April 2025.
There is dedicated Website created of Polish Ministry of Finance https://ksef.podatki.gov.pl where technical aspects of KSeF are published (the application for the taxpayers also for mobiles, technical instructions relating to integration of the taxpayers ERP system with KSeF and other needed information).
KSeF is an electronical platform run by the Head of the National Tax Administration (who is also the controller of data).
The purpose of KSeF is to issue and receive as well as store e-Invoices by the taxpayers. The other functionalities of KSeF for example:
- marking structured invoices with the identification number assigned in KSeF (KSeF Id. No.);
- assigning a collective identification number to at least two structured invoices issued by the taxpayer to a single recipient;
- verification of data of structured invoices used outside KSeF;
- analysis and control of the accuracy of data of structured invoices;
- granting, changing, or revoking authorizations to use the System;
serve to facilitate of using and management of the process of issuing and receiving e-Invoices via KSeF by the taxpayers.
The obligation to issue invoices via KSeF does not relate to:
- the taxpayers not established in Poland and not having the fixed establishment in Poland;
- the taxpayers having the fixed establishment in Poland if this fixed establishment does not participate in the supply of goods or services for which the invoice was issued;
- taxpayers using special schemas of VAT taxation (supply of services for not taxable persons by the non-EU suppliers, supply occasionally international transport of passengers, distance sales of imported goods);
- the taxpayers who supply to customers being individual person who does not carry out the business activity; transactions which are exempted from using KSeF (such as railway tickets, etc.);
- the taxpayers who are not obliged to issue invoice in KSeF based on specific provisions of Decree of Minister of Finance.
The taxpayers who are not established in Poland and not having the fixed establishment or having the fixed establishment in Poland which does not participate in the supply to which invoice is issued may issue and receive e-Invoices in KSeF voluntary.
On 28th January Polish Minister of Finance published a Tax Clarifications on the rules for determining involvement of the fixed establishment in the supply for the purposes of issuing and receiving e-Invoices via KSeF. The text of these Tax Clarifications is published under following link Pliki do pobrania KSeF 2.0 – KSeF (Krajowy System e-Faktur)
The structured invoice relating to supplies in respect to which:
- the place of supply is outside of Poland or
- the customer is not established in Poland and does not have the fixed establishment in Poland, or
- the customer is not established in Poland and have the fixed establishment in Poland if this fixed establishment does not participate in the supply of goods or services for which the invoice was issued,
should be issued in KSeF but delivered in different way (not in KSeF) agreed with the customer.
If the taxpayer issues the invoice in KSeF but delivers it to the customer in different/agreed way or uses the invoice outside of KSeF it is obliged to mark the invoice with the code assigned to the invoice in KSeF which allows on verification of the invoice.
How to get access to KSeF/Form ZAW – FA
To get access to KSeF, the taxpayer must file ZAW-FA form in which it indicate the authorized person to operate KSeF. If such taxpayer has „an electronic qualified stamp” containing a NIP of the taxpayer can use KSeF without filing ZAW-FA form.
The person reported in ZAW-FA will have the broadest possible scope of authority. All subsequent authorized persons or entities will be appointed by the person designated in the ZAW-FA. This person may grant the authorisation to operate KSeF electronically directly in KSeF platform.
All authorized persons must have a NIP or PESEL number or, if they have neither NIP nor PESEL, a qualified electronic signature (signatures granted in other EU countries will be also accepted).
ZAW-FA is filled only for one person.
Submission of a subsequent ZAW-FA form results in replacement of the person reported on the previous ZAW-FA form with the new person. Therefore, the subsequent ZAW-FA forms shall be submitted only if the taxpayer wants to cancel the authorization for the person previously indicated in the ZAW-FA.
If the taxpayer:
- fail to issue the structured invoice in KSeF, or
- issue the invoice during KSeF failure or unavailability not in line with the pattern specified for structured invoices;
- failed to send the invoice issued during the failure or unavailability of KSeF to KSeF within the required deadline;
the Head of the Tax Office imposes (by decision) a fine:
- of up to 100% of the amount of VAT shown on the invoice issued outside KSeF, or
- of up to 18.7% of the total amount due on the invoice issued outside KSeF if there is no VAT on the invoice.
The penalty must be paid without a summons to the tax office’s account within 14 days from the date of delivery of the decision.
The above regulations come into force on January 1, 2027.
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. Independent Tax Advisers Doradztwo Podatkowe Sp. z.o.o. and Integra International, and their related entities, are legally separate and independent entities.
© 2026 Integra and Independent Tax Advisers Doradztwo Podatkowe Sp. z.o.o.
About the Author:
Dorota Baczewska-Golińska
EDUCATION
She is a graduate of the Faculty of Law and Administration at Warsaw University.
EXPERIENCE
She has multiyear experience in tax advice gained at Ernst & Young S. z o.o.. She conducted a number of training courses on changes in VAT legislation after Poland’s accession to the European Union. Dorota provided services to companies from construction, automotive, gas & oil and IT sectors.
In 2003, she was entered in the list of licensed tax advisers under No. 09944.
SPECIALIZATION
Dorota specializes in VAT, excise tax and customs duties and is a tax advisor. Dorota is an expert in VAT aspects, including regulations in force in the European Union. Providing day-to-day tax advice and carrying out tax reviews are Dorota’s main tasks. She conducts regular VAT training sessions organized by VAT Forum where she is the Partner.
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.
We provide services to large international businesses, Polish companies and to small- and medium-sized entrepreneurs looking for assistance in developing their newly incorporated undertakings. We assist our Clients in every step of their activity and growth. We advise them on planned and performed transformations, mergers and acquisitions, as well as in the process of liquidation of economic entities.
We offer our Clients comprehensive tax advisory services. We have established specialisation teams supervised by our experienced tax experts. We have an individual approach to each Client and matter in which we are involved. Thanks to our consultants’ experience we can look at tax issues from the broadest possible perspective.
Members of the team of INDEPENDENT TAX ADVISERS Doradztwo Podatkowe Sp. z o.o. are tax advisers and experienced consultants who have gained their professional know-how in well-known advisory firms of the so-called Big Four. Our specialists are recognised authors of numerous professional publications. Our team members provide tax training and are invited to participate in numerous conferences in Poland and abroad.
Integra International Bio:
Independent Tax Advisers Doradztwo Podatkowe Sp. z.o.o.:
