Four New Regulations finalised for E-Invoicing Framework in Poland
In December 2025, Poland’s Ministry of Finance and Economy finalised the legislative landscape for the National e-Invoicing System (KSeF) by signing four critical executive regulations. These regulations establish the final operational framework for the mandatory KSeF 2.0 system, set to begin its phased rollout on February 1, 2026.
The Four New Regulations
The final package published in the Journal of Laws includes:
– The “Using KSeF” Regulation: This outlines procedures for managing system access, authentication methods (including new certificates), and technical rules for sharing invoices outside the central system.
– The Exemptions Regulation: This identifies specific transactions exempt from the structured e-invoicing mandate due to technical constraints, such as highway tolls, passenger transportation tickets (train, bus, air), and certain financial or insurance services.
– The “Invoice Issuance” Amendment: This updates rules for simplified invoices, requiring they include the issuer’s Tax ID (NIP) starting in February 2026 if issued within KSeF.
– The JPK_VAT Reporting Update: This adapts the reporting standards to include unique KSeF identification numbers and specific markers for any invoices issued outside the system.
Implementation Schedule
The KSeF 2.0 mandate follows a strict implementation timeline based on 2024 turnover:
- 1st February 2026: Mandatory for large taxpayers with a 2024 gross sales value exceeding PLN 200 million.
- 1st April 2026: Mandatory for all other VAT-registered entities, including SMEs and sole proprietors.
- 1st January 2027: Mandatory for micro-entrepreneurs with monthly sales under PLN 10,000.
Key Operational Changes for 2026
– New FA(3) Schema: The existing FA(2) structure will be entirely replaced by the FA(3) schema on February 1, 2026.
– Mandatory Receipt: Regardless of when the invoice must be issued, all entrepreneurs are required to be capable of receiving e-invoices through KSeF starting February 1, 2026.
– QR Code Requirements: Invoices issued or visualised outside the system must feature QR codes for verification. A new “Offline24” mode allows for issuing invoices during system failures, provided they are uploaded within one business day.
– Soft Launch Period: Penalties for non-compliance and the requirement to include KSeF numbers in payment titles are largely deferred until January 1, 2027, providing a one-year grace period for businesses to stabilise their processes.
Organizations are advised to use the KSeF 2.0 API for testing and to apply for necessary authentication certificates well before the February 2026 deadline.