Pro forma invoices will continue to be allowed as non-tax, purely informational business documents, but they will not be issued or processed in KSeF because they are not recognized as invoices under the VAT Act. From 2026 onwards, only legally defined VAT invoices will pass through KSeF, while pro formas may still be shared externally (PDF, email, systems) as offer or preview documents.
Pro Forma Invoices and E-invoicing: what changes after February 1, 2026?
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Poland
Author: Nikolina Basić
Category:
Fiscal subject related
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1062
Content accuracy validation date:
27.11.2025
Content accuracy validation time:
08:04h
For many years, pro forma invoices have been used in business as an information document – often serving as a preview of a final sale or order confirmation. With the upcoming launch of the National e-Invoice System (KSeF), entrepreneurs are asking: will pro forma invoices still be possible?
As a reminder, the rollout of mandatory KSeF will happen in stages:
- February 1, 2026 – large companies with turnover above PLN 200 million in 2024,
- April 1, 2026 – all taxpayers,
- January 1, 2027 – the smallest businesses with monthly sales under PLN 10,000 gross.
The VAT Act does not recognize pro forma invoices as tax documents. They are simply business practice. According to Article 106b of the VAT Act, invoices must be issued for sales, deliveries, or services. Pro forma invoices do not meet these requirements.
The National Information System confirmed in 2022 that pro forma invoices:
- are not invoices under the VAT Act,
- do not create tax consequences,
- do not allow VAT deduction,
- do not confirm a sale.
They remain only informational documents.
E-invoicing: KSeF will handle only invoices defined by law: standard invoices, electronic invoices, and structured invoices. Since pro forma invoices are not legal invoices, they cannot be issued in KSeF.
The Ministry of Finance has clarified: “A pro forma is not an invoice within the meaning of the VAT Act. Therefore, the issuance of such documents is not provided for in the KSeF.”
Pro forma invoices will still be legal and usable in business. They can be issued in PDF, accounting systems, or by email as offer documents. The only change is that they will not appear in KseF-E-invoicing.
VAT invoices, on the other hand, must meet strict rules of authenticity, integrity, and readability. Pro forma invoices are excluded from these rules because they are not tax documents.
In summary: pro forma invoices remain valid for business use, but they will not be part of the KSeF system starting in 2026.
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