On 27 August 2025, Poland signed into law amendments to the VAT Act and the KSeF Act, introducing transitional provisions and technical updates to the country’s mandatory e-invoicing regime. The new legislation reinforces the use of the National E-Invoicing System (KSeF – Krajowy System e-Faktur) while providing flexibility for smaller businesses and specific use cases.
Phased Adoption for Businesses
The amendments establish a phased approach for issuing traditional invoices alongside KSeF:
- 1 February – 31 March 2026: Taxpayers with total 2024 sales and VAT below PLN 200 million (approx. USD 54.6 million) may continue issuing paper or standard electronic invoices.
- 1 April – 31 December 2026: Taxpayers whose monthly total sales and tax remain under PLN 10,000 (approx. USD 2,732) may use traditional invoicing.
- 1 February – 31 December 2026: Businesses may issue paper or electronic invoices linked to cash register receipts, provided they meet fiscal cash register requirements.
Technical Updates
The law also introduces technical changes, including revisions to the Offline24 mode to improve reliability when real-time KSeF submissions are not possible. Updates to the deposit-refund system ensure compatibility with structured e-invoicing requirements.
Mandatory KSeF Use and Compliance
The Act confirms the phased mandatory use of KSeF for B2B transactions:
- 1 February 2026: Largest taxpayers (2024 sales exceeding PLN 200 million) must comply.
- 1 April 2026: Other businesses must begin mandatory use, excluding the smallest enterprises, which are deferred until 1 January 2027.
- VAT-exempt taxpayers will have an additional six months, with mandatory KSeF use starting 1 January 2025.
Background
Poland’s e-invoicing rollout began with voluntary structured e-invoices through KSeF in January 2022. The first mandatory B2B e-invoices under KSeF were introduced on 1 July 2024. These updates aim to strengthen VAT compliance, reduce fraud, and streamline invoice validation for taxpayers.
The law generally takes effect the day after its publication in the official gazette, signaling the start of implementation work for businesses to meet new obligations and manage related risks effectively.
