Electronic invoicing (e-invoicing) in Poland is undergoing a significant transformation, with the National e-Invoicing System (KSeF) at its core. This system is set to revolutionise how businesses issue, receive, and store invoices, aiming to enhance tax collection, combat VAT fraud, and streamline administrative processes.

This guide provides a detailed overview of the key e-invoicing requirements in Poland, including mandatory rules, standards, and compliance considerations.

Mandatory e-invoicing for public transactions
E-invoicing standards and networks
Mandatory e-invoicing for private sector (B2B) transactions
Voluntary adoption for consumer invoicing (B2C)
Tax and compliance considerations
Conclusion

Mandatory e-invoicing for public sector (B2G) transactions 

As of April 1, 2019, all suppliers sending invoices to the Polish public sector, including government agencies, municipalities, and regions, must submit their invoices electronically. This requirement is in line with EU Directive 2014/55/EU, which standardises e-invoicing across the European Union.

• Platform: B2G electronic invoicing is primarily facilitated through the PEF (Platforma Elektronicznego Fakturowania) platform, which operates within the OpenPeppol network.
• Standard format: The standard format required for public sector e-invoicing is Peppol BIS Billing 3.0, which ensures interoperability with other European systems. Businesses working with Polish public entities must ensure their e-invoicing solutions are compliant with this format.

E-invoicing standards and networks

Poland utilises a dual approach to e-invoicing standards:

• Peppol: The OpenPeppol network and its Peppol BIS Billing 3.0 standard are crucial for B2G transactions through the PEF platform. The Ministry of Economic Development and Technology acts as the Polish Peppol Authority. This also makes Peppol highly relevant for cross-border B2B transactions with partners in other Peppol-enabled countries.

• KSeF XML (FA(3)): For domestic B2B transactions, the KSeF system mandates its own proprietary XML format (FA(3)). While distinct from Peppol BIS Billing, many e-invoicing solution providers offer integration that can convert existing invoice data (e.g., from ERP systems or other formats) into the required FA(3) XML for KSeF submission.

Mandatory e-invoicing for private sector (B2B) transactions

The most significant change in Poland's e-invoicing landscape is the upcoming mandatory use of the National e-Invoicing System (KSeF) for domestic B2B transactions. This mandate will be introduced in phases:

• February 1, 2026: Mandatory for large taxpayers (businesses with annual turnover exceeding PLN 200 million, approximately EUR 46 million, in 2024).

• April 1, 2026: Mandatory for all other VAT-registered taxpayers.

• January 1, 2027: Micro-businesses (invoices under PLN 450 or with monthly sales under PLN 10,000) have a deferred start

Key Aspects of KSeF for B2B:

• Centralised system: All domestic B2B e-invoices must be issued and received through the KSeF system.

• Required format: Invoices submitted to KSeF must adhere to the specific XML format (FA(3) logical structure) defined by the Polish Ministry of Finance. 

• Official receipt: Upon successful submission to KSeF, the invoice issuer receives an official confirmation (UPO) with a unique KSeF ID, which serves as proof of issuance.

• Offline mode: A permanent offline mode will be available, allowing businesses to issue invoices outside KSeF (e.g., during system downtimes) and submit them to KSeF by the following business day.

• Foreign entities that are VAT-registered in Poland but do not have a "Fixed Establishment" (FE) in Poland are exempt from the mandatory KSeF system.

   

• Attachments: The new FA(3) schema allows for structured attachments (e.g., contracts, delivery protocols) to be submitted with e-invoices.

Voluntary adoption for consumer (B2C) invoicing 

Issuing consumer invoices through KSeF is optional. Businesses can continue to issue paper or PDF invoices for B2C transactions.

However, if a B2C e-invoice is issued via KSeF upon a consumer's request, it will need to be delivered outside KSeF (e.g., via email) with a QR code for consumer verification.

Tax and compliance considerations

E-invoicing in Poland must strictly comply with Polish VAT laws and the record-keeping requirements set by the Polish Tax Agency.

• Archiving period: The official archiving period for electronic invoices in Poland is 5 years. However, the KSeF system will serve as a central repository, storing electronic tax documents for 10 years.

• KSeF ID in payments: The requirement to include the KSeF invoice number in payment titles has been postponed. It is now set to become mandatory from January 1, 2027. This allows businesses more time to adapt their payment systems.
  
  

• Penalties: Penalties for non-compliance with the KSeF mandate (e.g., failure to issue e-invoices via KSeF, late submission of offline invoices) are suspended until the end of 2026. From January 1, 2027, penalties will apply, potentially including fines.

• Benefits for voluntary users: Businesses voluntarily using KSeF before the mandate can benefit from a reduced VAT refund period (40 days instead of 60) and an exemption from the JPK_FA (SAF-T) file declaration obligation.

Conclusion

Poland's e-invoicing journey, spearheaded by the KSeF system, represents a significant leap towards digitalising its economy and strengthening tax compliance. Businesses operating in Poland must prepare diligently for the phased implementation of KSeF for B2B transactions while continuing to meet B2G e-invoicing requirements via Peppol.

Maventa’s e-invoicing solutions make invoicing effortless: you can connect seamlessly to Peppol and local networks like KSeF to expand your system’s reach. With just one integration, you can offer the best invoicing experience in the market for your customers, ensuring compliance and efficiency across all your transactions.