Fiscal subject related
In response to public consultations held in April 2025, the Polish Ministry of Finance released a new package of documents on May 30, 2025, related to the rollout of mandatory B2B e-invoicing via the National e-Invoicing System (KSeF).
What was published?
- A new draft law: KSeF 2.0 Project,
- Two implementing regulations:
· Identification rules for e-invoice issuers,
· Document authentication requirements,
- Results from April 2025 public consultations,
- Impact assessments for the new law,
- Introduction of a deposit system and changes to VAT settlement timelines,
- An updated ZAW-FA form for managing user permissions,
- Natural persons added as recognized buyers in B2B transactions,
- Adjustments to micro-business limits: simplified threshold of PLN 10,000/month, removing the PLN 450 per-invoice cap,
- More relaxed rules for Offline24 mode,
- Clarifications on transactions that will not fall under KSeF obligations.
Timeline:
May 2025
- Continued public consultations,
- Draft of the new FA(3) invoice format.
June 2025
- Publication of updated draft legislation,
- Release of API documentation and testing timeline,
- Final version of the FA(3) schema.
July 2025
- Final law to be approved.
End of September 2025
- Public testing phase of KSeF 2.0 API begins.
November 2025
- Taxpayers can apply for issuer certificates,
- Public testing of KSeF mobile app,
- KSeF 2.0 production environment becomes available.
Go-Live Phases:
- February 1, 2026: Mandatory for large businesses (with over PLN 200 million turnover in 2024),
- April 1, 2026: Mandatory for all other taxpayers.
Additional Rollouts:
- August 1, 2026: Required to include KSeF invoice IDs in bank transfers,
- January 1, 2027:
· Microbusinesses must use KSeF if issuing over PLN 10,000/month,
· Penalty system starts for businesses that were required to join in 2026,
· Offline24 mode becomes a permanent option, allowing next-day invoice submission (including split payments). Special approval will be required starting November 1, 2025,
· A standardized QR code must be included on all printed or PDF versions of e-invoices,
· Delayed requirements begin:
§ Reporting e-invoices through cash registers,
§ Enforcing KSeF number on invoice payments,
§ Penalties for non-compliance with KSeF rules,
· Optional rollout of B2C e-invoicing via KSeF.
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