Fiscal subject related
The Polish Ministry of Finance (MoF) has confirmed its commitment to implementing the National e-Invoicing System (KSeF), with mandatory adoption still set to begin in February 2026, despite slight delays in finalizing the legislation.
Revised Timeline: The draft legislation, initially expected in Q1 2025, will now be submitted to the Council of Ministers in Q2 2025, potentially after another round of public consultations.
As we stated before, the Ministry of Finance presents the current status of the draft legal, technical, and business solutions and the plan to implement the mandatory KSeF system.
During the verification of the business and technical assumptions of the project, the ministry took into account all the key demands submitted by entrepreneurs regarding the issuance of e-invoices in KSeF.
Entrepreneurs may submit additional comments and opinions on the project until 25 April 2025 by writing to sekretariat.PT@mf.gov.pl
After analyzing the possibilities of changes from a business and legal perspective and analyzing the technical possibilities of preparing the system, the Ministry of Finance confirms the introduction of the obligation to issue e-invoices for all taxpayers (active and exempt from VAT) in two main stages with an additional postponement for the smallest entrepreneurs:
Mandatory rollout:
· Large taxpayers: Required to use KSeF starting 1 February 2026.
· All other businesses: Deadline set for 1 April 2026.
However, the ministry is still analyzing input from the November 2024 public consultations but has not yet addressed updates to the FA(3) technical schema, a critical component for system integration.
Also, the ministry emphasized plans for information campaigns to help businesses prepare, though specific details remain undisclosed.
It is planned that in Q2 2025 there will be revised legislation, expected to proceed to the Sejm (Polish parliament), and for 2026, phased mandatory adoption begins.
Also, the ministry states that, from September 30, it will be possible to test the programming interface (API) of KSeF 2.0 (which will be available for use from February 1, 2026) in an open manner by all integrators and large companies.
In turn, from November 2025, it is planned to provide a test version of the KSeF 2.0 Taxpayer Application so that all entrepreneurs can learn about the solutions and functionalities of the system. Such a solution will allow taxpayers to prepare for the mandatory KSeF in advance, familiarize themselves with the operation of the appropriate software, and learn about the functionalities that they will use from February 1, 2026, or from April 1, 2026. Thanks to this, taxpayers will be able to use the system more confidently and effectively after its introduction. Invoices issued in the KSeF 2.0 test environment (API interface and KSeF Taxpayer Application) will not have any legal effects. The production version of the system, i.e., allowing for issuing invoices in real economic transactions, will be made available on 1 February 2026. From that moment on, entities covered by mandatory invoicing, in accordance with the presented schedule, will be obliged to issue invoices in KSeF.
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