Poland's Ministry of Finance releases the KSeF 2.0 draft and important updates.

On May 30, 2025, the Polish Ministry of Finance released the KSeF 2.0 package following April's public consultations, introducing a new draft law, implementing regulations, updated thresholds, and technical guidance for the mandatory B2B e-invoicing rollout. The phased implementation begins in February 2026 for large businesses, expanding to all taxpayers by April 2026, with further obligations and penalties taking effect through January 2027.

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.