On 12 April 2025, the Polish Ministry of Finance published the implementation plan for their National e-Invoicing System (KSeF 2.0). This marks a significant step in Poland’s digital tax transformation – and businesses need to act now to prepare.
Key eInvoice implementation dates:
- 30 September 2025: The KSeF API opens to developers. This is the starting point for building or updating compliant invoicing systems.
- 1 November 2025: A test environment becomes available. Businesses can issue e-invoices in the required format, but they will not carry legal weight.
- 1 February 2026: Large companies (annual turnover exceeding 200 million PLN) are required to issue e-invoices through KSeF 2.0.
- 1 April 2026: Mandatory adoption expands to all other businesses and entrepreneurs.
Exemptions and optional adoption:
- Small enterprises with monthly turnover under 10,000 PLN and issuing invoices below 450 PLN are exempt.
- Flat-rate scheme farmers and agricultural enterprises may opt in voluntarily.
Paper invoices phase-out:
From 1 December 2027, paper invoices will no longer be accepted. All invoices must be issued electronically via FSeF 2.0.
Compliance & Certification
To issue e-invoices via KSeF 2.0, businesses must be certified. Certification is essential for:
- Secure access and authentication
- Using Offline24, a fallback solution that allows continued invoicing during system outages or when billing foreign entities (that don’t require a NIP)
What else is changing?
- Penalties will apply for e-invoice errors.
- KSeF invoice numbers will become mandatory for payments, including split payments.
- An attachment system will be introduced – allowing additional files to be submitted with invoices.
This is especially relevant to sectors like energy, fuel, construction and telecommunications, where supporting documentation are often required.
Importantly, the system is designed to be secure – and does not require detailed time or activity data for billing purposes.
Cross-border considerations
According to the KSeF 2.0 FAQ, published on 18 March 2025, VAT ID-only registered non-resident companies are not required to issue e-invoices for their economic activity in Poland.
Looking ahead
KSeF 2.0 is not a statis system – it is evolving. The Ministry of Finance continues to refine the platform and invites feedback from businesses to shape its future.
Work with indirect tax experts
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Authors
Lisa Dowling
Specialising in International VAT Compliance solutions, Lisa brings a wealth of knowledge and insight in her dealings with a host of international clients ranging from start-ups through to multinationals. With 21 years VAT experience behind her, Lisa has managed VAT compliance issues and solutions globally for for over 11 years. Fintua have 12,000 + corporate clients in over 109 countries and many of these are members of the Fortune 500.
