Poland's invoicing e-regulation timeline

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🇵🇱 Invopop resources for Poland


Compliance	Invoicing compliance in Poland Compliance timeline
Apps	Poland
Guides	Poland Guide
FAQ	Poland FAQ
GOBL	Poland Tax Regime Polish KSeF FA(3) Addon

Executive summary

Poland is transitioning to KSeF 2.0: a centralized, clearance-based system that routes B2B invoices through a single state hub. E-invoices will replace traditional PDFs as structured documents of XML code, presented in the Polish FA(3) schema. The reform aims to curb VAT fraud, improve transparency, and standardize digital invoicing across the economy. To improve adoption, KSeF offers multiple issuance channels including the e-Faktur web portal, a dedicated API for ERP integration, and an official mobile app. QR codes and a 24 hour offline modes have also been developed for easy verification and to maintain functionality during temporary network outages. Key insights:

Every Polish business is required to receive e-invoices from 1 February 2026.
The start date for issuing e-invoices is phased: large companies (over PLN 200M annual sales) from 1 February 2026, other taxable companies from 1 April 2026, and micro entrepreneurs from 1 January 2027.
B2C transactions are out of scope.
Cross-border transactions (B2Bi) invoices are generated through KSeF.
B2G e-invoicing continues through the PEF platform, which is now linked to KSeF.
Penalties are suspended during 2026 (grace period). From 1 January 2027, non-compliance fines can reach up to 100% of the VAT amount shown on non-compliant invoices (or 18.7% of gross value for zero-rated transactions).

E-invoicing in Poland

Poland has used e-invoicing for the public sector since 2019, and as of February 2026, the requirement extends to domestic B2B transactions. Businesses grant the required authorizations (with a KSeF token or certificate), and the system validates, transmits, and receives each e-invoice, ready to view in a company’s accounting system. Each invoice is validated by the tax authority before it reaches the customer; once cleared, it receives a unique KSeF identifier and is considered legally issued.

KSeF (B2G, B2B)

B2G e-invoices are issued through PEF, the public sector platform. As of the new mandate, PEF will synchronize with KSeF to apply the same validation sequences, so public entities can decide to use either portal.


Models	B2G, B2B
Format	FA(3) XML
Infrastructure	KSeF
Model	Clearance continuous transaction control (CTC)
Scope & Deadline	Mandatory for B2G invoices since 2019; phased from February 2026-2027 for B2B transactions
Agency	Polish Ministry of Finance
Invopop support	Contact us for details

E-reporting

Involves sending invoice data to tax authorities in real-time or near real-time, typically as part of government initiatives to improve tax compliance and reduce VAT fraud.

SAF-T Poland

Known locally as JPK (Jednolity Plik Kontrolny), SAF-T is a mandatory electronic reporting system standardizing how businesses submit accounting data to the tax authorities. Companies must send XML files directly from their accounting systems, using schemas defined by the ministry. The core file, JPK_VAT, is submitted monthly and details all VAT transactions, while other versions (e.g., JPK_KR for general ledger, JPK_FA for invoices) can be requested during audits. Since October 2020, the JPK_V7 format has merged VAT reporting and return obligations into a single file, combining transactional data with declaration elements for both VAT-registered entities and smaller taxpayers.


Format	SAF-T (XML)
Scope & deadline	Mandatory since 2020 for all taxpayers
Invopop support	No

Regulation

International transactions (B2Bi)

For international transactions, the invoice is created and cleared in KSeF just like a domestic one. Once the invoice is validated, the tax data is recorded and it receives a KSeF ID to prove compliance.Because a foreign recipient without a Polish NIP (tax ID) cannot log in to KSeF, delivery takes place outside the platform. The commercial channels continue as before: via email, EDI attachment or paper. The document must include the KSeF references, in particular a QR code, so the buyer can scan the document and view a verifiable version online.

Legally required e-invoice content

An e-invoice contains the same business information as a traditional invoice, but must follow the FA(3) XML structure.

Date and time (in the YYYY-MM-DDTHH:MM:SS format).
Optional: Name of the ICT software used by the taxpayer.
Supplier information (NIP).
Buyer information (NIP).
Third parties relating to the invoice if applicable (such as an e-invoicing provider).
Information regarding transaction terms.
KRS number: The invoice footer (“Stopka”) includes an optional “Rejestry” block for registry identifiers such as KRS and REGON.
Optional: From 1 February 2026 the optional “Zalacznik” element may be used where a transaction involves a complex set of data for units of measure, quantities, or net unit prices. Attachments are part of the structured file and are limited to data closely related to tax content. Prior notification (via e-Urząd Skarbowy) is required to enable attachments, and each attachment cannot exceed 3 MB. Non-tax materials (e.g., contracts or marketing content) are not allowed as invoice attachments.

When you're not required to issue e-invoices via KSeF

B2C transactions
Non-established businesses

For a full list of exemptions, see the “scope” page on the KSeF website.

KSeF certificates

KSeF certificates are digital documents that authenticate a company in the KSeF portal.Type 1 certificateThe designated individual of each company will apply for a type 1 certificate to use the KSeF API in an ERP or accounting software. Access is granted after the authorized person confirms their identity with a certified e-signature. KSeF certificates are available to download online from 1 November 2025 and will be added directly to the KSeF API from February 2026. Type 2 certificate For offline invoices, businesses send a type 2 certificate that includes two QR codes for customers to scan on their phone: one QR code for the buyer to access the invoice online, another to validate the supplier’s identity.

For more information see the government FAQs section on e-invoice QR codes.

B2C transactions (Fiscal cash registers)

B2C transactions are excluded from the e-invoicing mandate. The Polish tax authority already receives B2C sales data from online fiscal cash registers that continuously transmit receipts to the Central Repository of Cash Registers (CRK).For B2B transactions, receipts that include a buyer NIP below PLN 450 remain compliant as simplified invoices until 31 December 2026. Companies will need to submit these transactions via KSeF from 2027.

Non established businesses (no FE)

A foreign entity is not required to issue invoices in KSeF if it has no registered office and no fixed establishment in Poland. It is also outside the mandate if it has a fixed establishment in Poland that does not participate in the specific supply. Such businesses still may opt to issue invoices through KSeF voluntarily. A fixed establishment is defined as having “sufficient permanent presence with human and technical resources”. As the assessment is case-by-case, the Ministry of Finance has indicated it will publish additional explanations on the fixed establishment criteria.

Penalties and enforcement

Poland has implemented a grace period for KSeF adoption: no penalties or formal sanctions will be imposed during 2026. This allows businesses time to adapt their systems and processes without financial risk.Starting 1 January 2027, the Ministry of Finance will enforce compliance with financial penalties:

Fines up to 100% of the VAT amount shown on invoices not issued via KSeF when required.
For zero-rated or VAT-exempt transactions, fines up to 18.7% of the gross invoice value.
Tax authorities have discretion to adjust penalties based on severity and circumstances.

Additional consequences:

Invoices not issued through KSeF may be considered invalid for VAT deduction purposes.
Business partners may refuse to accept non-compliant invoices.
Tax office audits from 2027 onwards will incorporate KSeF compliance checks.

Operational notes: QR codes, offline mode, and archiving.

QR codes: KSeF provides QR codes for B2Bi transactions to verify whether a document exists in the system and, for offline issuance, to authenticate the issuer. Offline invoices show two QR codes (“OFFLINE” and a certificate QR) until they are delivered to KSeF.
Offline procedures: In addition to real-time online clearance, KSeF supports: (1) offline24 (to issue now, upload by end of the next business day), (2) scheduled maintenance offline (to upload the day after maintenance ends), and (3) emergency mode (to upload within seven business days after an official outage).
Retention: Invoices accepted by KSeF are archived and available in the system for 10 years.

Related resources

FAQ

Compliance questions

When does mandatory KSeF invoicing start in Poland?

1 February 2026 for taxpayers with turnover above PLN 200M and 1 April 2026 for everyone else (large/medium businesses) — schedule confirmed by Sejm in mid-2024 after delays. B2C is optional. Foreign-only businesses without a fixed Polish establishment are out of scope.

Who can act as a supplier in Poland?

Any entity with a Polish NIP and active KSeF access. Large taxpayers (turnover > PLN 200M) must be onboarded by 1 February 2026; the rest by 1 April 2026. Foreign-only entities without a Polish fixed establishment cannot use KSeF.

What are the legal obligations for receiving invoices in Poland?

Once KSeF is mandatory, all B2B invoices must be received through KSeF — paper or PDF rejection is no longer permitted between Polish parties. Archival is automatic in KSeF for 10 years; recipients can pull copies at any time.

What periodic reporting obligations exist in Poland?

JPK_V7M (monthly) or JPK_V7K (quarterly) consolidated VAT and SAF-T file. Once KSeF is mandatory, JPK_V7 is expected to draw directly from KSeF data, eliminating manual reconciliation.

What types of invoices are supported in Invopop's KSeF integration?

Currently supported invoice types:

Standard Invoices (FAT): Regular B2B invoices with FA(3) schema
Credit Notes (KOR): Invoice corrections and adjustments

All invoices must include the pl-favat-v3 addon in GOBL to ensure FA(3) schema compliance.

Additional invoice types can be supported based on customer requirements. Contact support if you need specific invoice types.

Will B2C transactions need to be reported in KSeF?

No. B2C invoices in KSeF are optional. The mandatory requirement applies only to B2B transactions.

Are there special supplier obligations under KSeF?

The KSeF certificate must belong to the company account directly or to a user with both InvoiceRead and InvoiceWrite permissions in KSeF. Suppliers must declare KSeF as their issuer in the Ministry of Finance taxpayer’s portal before going live.

What are the legal obligations for receiving invoices through KSeF?

Once KSeF is mandatory, all Polish B2B recipients must accept KSeF-issued invoices. KSeF itself archives for 10 years; recipients have no separate archival duty for the structured XML.

More available in our Poland FAQ section

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