Poland has released new draft legislation for KSeF 2.0, introducing key updates such as Offline24 invoicing, stricter correction invoice rules, expanded eligibility for receiving invoices outside KSeF, and new authentication requirements. The updated framework, part of Poland's mandatory e-invoicing rollout planned for February or April 2026, also includes provisions for structured attachments, exemptions for digitally excluded taxpayers, and optional KSeF participation for certain cross-border transactions.
Poland updates KSeF 2.0 with new draft legislation.
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Poland
Author: Nikolina Basić
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Fiscal subject related
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Content accuracy validation date:
26.06.2025
Content accuracy validation time:
08:27h
Poland is pushing ahead with its nationwide e-invoicing mandate as the Ministry of Finance released a trio of draft legislative acts on May 30, 2025, marking a step in the rollout of KSeF 2.0—the next phase of the National e-Invoicing System. The Polish E-invoicing System KSeF will be implemented in Poland on February 1st or April 1st, 2026.
The package includes a revised draft amendment to the VAT Act and two executive regulations that outline operational guidelines and exemptions related to KSeF usage.
Following public consultation, several notable revisions were introduced:
· Offline24 Mode: Invoices may now be issued outside the KSeF system when necessary, provided they are submitted to KSeF by the end of the next business day.
· Corrective Invoices: Tax reductions for buyers will only apply after they receive the appropriate correction invoice from suppliers.
· Eligibility to Receive Invoices Outside KSeF: Expanded to include individuals without a Polish NIP and non-business natural persons, provided mutual agreement exists with the issuer.
· KSeF ID Requirement: Third-party payers must reference the KSeF number or collective ID when processing bank payments.
· Digitally Excluded Taxpayers: The PLN 450 per-invoice exemption is extended through the end of 2026, while the monthly turnover cap of PLN 10,000 remains unchanged.
The ministry also detailed new measures for KSeF implementation:
· Authentication Shift: As of December 31, 2026, token-based login methods will be replaced by certificate-based authentication, with a validity of two years.
· External e-Invoice Marking: When technical limits prevent embedding QR codes, external invoices may include URL links instead.
· Structured Attachments: Taxpayers must notify the e-Tax Office before issuing invoices with structured attachments, which are limited to one attachment (max 3MB) per invoice.
· Authorization for Foreign Taxpayers: Non-Polish VAT-registered businesses may issue self-billed invoices using their EU VAT numbers.
The primary purpose of processing personal data in KSeF is to enable tax authorities to fulfill their legal obligations, mainly by verifying the accuracy of business tax settlements. As a result, invoices issued by taxpayers in KSeF will only be reviewed in connection with the verification of the taxpayer's tax returns;
Personal data from B2C invoices will be processed minimally, as issuing consumer invoices in KSeF is optional and requires a consumer's request; additionally, most invoices in KSeF will concern B2B transactions.
New provisions under Article 106s of the VAT Act allow cross-border self-billing transactions—in cases where either the buyer or supplier lacks a Polish NIP—to be exempt from KSeF requirements. However, foreign buyers using an EU VAT ID may still opt into the system voluntarily.
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