Change of the cash register technical requirements in Poland as the e-invoicing transition ends in 2027

Poland is preparing changes to the technical requirements for cash registers ahead of 1 January 2027. The changes will remove cash-register invoice functions and align fiscal devices with the end of transitional KSeF rules, while fiscal receipts and CRK reporting remain in place.

Poland is preparing amendments to the technical requirements applicable to cash registers (as part of the transition to the target KSeF e-invoicing model. The changes are connected with the expiry of temporary rules that allow invoices and simplified invoices to continue being issued through cash registers during 2026.

The amendments are intended to apply from 1 January 2027, when several important KSeF transitional measures expire. The main purpose is to remove invoice-related functions and terminology from the technical cash-register framework and adapt cash registers to their future role, which will remain focused primarily on recording sales, issuing fiscal receipts and transmitting required fiscal data.

It is presented in the Draft Regulation of the Minister of Finance and Economy amending the Regulation on technical requirements for cash registers.

One of the most important changes concerns the possibility of issuing invoices using fiscal cash registers: 8under the KSeF transitional rules, until 31 December 2026, taxpayers that are otherwise required to issue structured invoices can continue issuing invoices through cash registers without transmitting those invoices through KSeF. This transitional treatment also covers fiscal receipts containing the buyer's NIP up to PLN 450 (EUR 100), which may currently qualify as simplified invoices.

This exception ends on 1 January 2027-from that date, invoices relating to sales to taxpayers that are subject to mandatory KSeF will no longer be issued through cash registers. Where an invoice is issued for a transaction recorded using an online fiscal cash register, the invoice must be issued through KSeF if the sale is made to a taxpayer and falls within the mandatory system. Consequently, the technical requirements for cash registers are being adapted so that invoice-related functionality is no longer part of the required cash-register fiscal functionality.

Fiscal receipts containing the buyer's NIP-tax identification number will not disappear. From 1 January 2027, businesses will still be able to issue fiscal receipts containing the buyer's NIP. However, these documents will no longer qualify as simplified invoices , regardless of the current PLN 450 threshold. The distinction is important for retailers. A fiscal receipt with NIP will remain a fiscal receipt, but where a B2B invoice is required and mandatory KSeF applies, a separate structured invoice will have to be issued through KSeF. The Ministry of Finance's KSeF 2.0 Handbook explicitly confirms that, from 1 January 2027, invoices can no longer be issued using cash registers and fiscal receipts containing the buyer's NIP can no longer be treated as simplified invoices.

Next, references to invoices and cancelled invoices are being removed from relevant cash-register requirements. The corresponding technical provisions will instead focus on fiscal receipts and cancelled fiscal receipts. The changes affect several areas of cash-register operation, including the information recorded in fiscal memory, document-related data and the functions that fiscal devices must support

The amendments also address communication between online cash registers and the Central Repository of Cash Registers. The technical provisions are being clarified to link data transmission more explicitly to the applicable communication protocol. This is relevant to the technical operation of online cash registers and the manner in which required fiscal information is transmitted to the central system.

KSeF and the fiscal cash-register system remain separate regulatory mechanisms. KSeF governs structured invoicing, while cash registers continue to perform their fiscal role for transactions that must be recorded through the cash-register system.

The amendment also includes changes concerning special-purpose cash registers, particularly devices used in activities where several transactions may be processed simultaneously, including restaurant and catering services.

Further adjustments concern cash-register fiscalization, fiscal receipt data, electronic forms of certain reports, fiscal-memory requirements and procedures related to the testing and approval of cash registers. Taken together, these changes are intended to ensure that the technical cash-register framework corresponds to the legal environment that will apply after the KSeF transitional period ends. Cash registers will continue to be relevant for fiscal sales recording and receipts, but their transitional role in issuing invoices will end.

Implementation impact and what businesses should do:

Retailers and POS providers should review whether their current cash-register solutions contain functionality for issuing invoices or treating receipts with NIP as simplified invoices. These processes should be adapted before 1 January 2027, particularly where B2B customers request invoices for transactions recorded at the POS.

Retailers will need to separate fiscal receipt processing from mandatory B2B invoicing more clearly. From 1 January 2027, cash registers will no longer provide the transitional invoice function, while receipts with NIP will remain possible but will no longer constitute simplified invoices.

This text is based on consultant research od the draft law. Source

Nikolina Basić, Senior Legal Consultant at Fiscal Solutions

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