08 September 2025

Poland signs into law mandatory national e-invoicing system

  • On 27 August 2025, Poland's President signed into law the amendment to the Value-Added Tax Act, establishing the Krajowy System e-Faktur (KSeF) as a mandatory national e-invoicing system, effective from 1 February 2026.
  • The phased rollout of KSeF 2.0 will require large taxpayers, with a turnover exceeding PLN 200m, to start issuing e-invoices by 1 February 2026, followed by all other VAT-registered businesses by 1 April 2026, excluding micro-entrepreneurs.
  • Micro-entrepreneurs must comply with the e-invoicing requirements starting 1 January 2027, which will include both business-to-business and business-to-government transactions processed through the KSeF platform.
  • Affected entities should prepare for the transition to the KSeF system by assessing their invoicing processes, ensuring technical integration by the specified deadlines and consulting with advisors to navigate the new compliance landscape effectively.
 

Executive summary

On 27 August 2025, the President of the Republic of Poland signed into law the amendment to the Value-Added Tax Act — officially turning the Krajowy System e-Faktur (KSeF) into a mandatory national e-invoicing system.

This is the final pivotal step that marks the start of Poland's phased transition to structured electronic invoicing under the upgraded KSeF 2.0 framework.

KSeF 2.0 rollout timeline and key milestones

Key dates in the development, launch and application of the new KSeF 2.0 framework are summarized below.

2025 — Preparatory phase

  • 30 June 2025
    • The Ministry of Finance released the final FA (3) structured invoice schema and KSeF 2.0 API documentation, enabling technical integration.
  • 30 September 2025
    • The new KSeF 2.0 API opens for public testing — integrators and larger companies can begin technical trials.
  • 1 November 2025
    • Test version of the KSeF 2.0 Taxpayer Application becomes available. Invoices issued in this test environment will not have legal effect.

2026 — Mandatory launch and scope

  • 1 February 2026
    • Large taxpayers (those with 2024 turnover exceeding 200 million Polish zloty (PLN200m), including value-added tax (VAT)), must begin issuing e-invoices via KSeF 2.0 in the production environment.
  • 1 April 2026
    • The mandate extends to all other VAT-registered businesses, excluding micro-entrepreneurs.
    • Additionally, from this date, VAT RR invoices (for agricultural purchases from flat-rate farmers) can be issued via KSeF.

1 January 2027

  • Micro-entrepreneurs (with monthly turnover ≤ PLN10,000 and invoice value ≤ PLN450) must start using KSeF.

Note that both business-to-business (B2B) and business-to-government (B2G) e-invoices should be processed and issued through the single KSeF platform. Therefore, the previous B2G "pef" platform will essentially become redundant.

Implications

Large businesses, with a turnover exceeding PLN 200m, should prepare to begin issuing e-invoices as of 1 February 2026. Most other VAT-registered businesses must comply by 1 April 2026, followed by micro-entrepreneurs beginning 1 January 2027.

Affected entities should prepare for the transition to the KSeF 2.0 system by assessing their invoicing processes, ensuring technical integration by the specified deadlines and consulting with advisors to navigate the new compliance landscape effectively. Failure to comply with the new regulations will result in a lack of ability to issue valid sales invoices, directly impacting the business cashflow. Complying with the KSeF regulations will also significantly impact the overall accounts receivable and accounts payable procedures within organizations, which should be redesigned accordingly and implemented in advance to avoid post-KSeF disarray.

* * * * * * * * * *
Contact Information

For additional information concerning this Alert, please contact:

EY Doradztwo Podatkowe Krupa sp.k., Warsaw

Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor

Document ID: 2025-1815