Fiscal subject related
The Polish Ministry of Finance has officially launched the first wave of mandatory B2B e-invoicing through the National e-Invoice System (KSeF). Large taxpayers with annual turnover above PLN 200 million are now required to issue invoices via KSeF. The rollout continues on 1 April 2026 for most other businesses, while micro-enterprises will join on 1 January 2027.
Key developments:
- 27 January 2026: The Ministry introduced KSeF Latarnia, a GitHub-based service providing technical access times and maintenance updates.
- 18 December 2025: Final regulations were published, covering exemptions, invoicing rules, and links to SAF-T VAT reporting.
Timetable highlights:
- 1 Feb 2026: Large taxpayers go live.
- 1 Apr 2026: Other taxpayers join.
- 1 Aug 2026: Bank transfer ID references must be added.
- Jan 2027: Micro businesses enter the system.
Scope of the mandate
- Mandatory: Domestic B2B supplies, sales to public bodies (B2G), and outbound cross-border transactions.
- Excluded: Domestic B2C invoices, inbound cross-border invoices from non-Polish suppliers, and certain exemptions such as small taxpayers or OSS/IOSS transactions.
Regarding technical standards, we can say that Invoices must follow the FA(3) XML schema, aligned with European standards (EN 16931, Peppol BIS). Each invoice receives a unique KSeF reference number and QR code for verification. No electronic signature is required, as authenticity is ensured by KSeF itself.
Compliance and penalties:
- 2026: Transitional relief – no monetary penalties for breaches.
- 2027 onwards: Administrative fines apply for non-compliance.
Retention: All invoices are stored centrally by the tax authority for 10 years, reducing the burden on businesses.
Businesses can connect via APIs, government portals, or simplified tools for micro-enterprises. Invoices are validated automatically; only approved invoices are legally recognised. Offline submission is permitted under the permanent Offline24 mode, with next-day uploads required.
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