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Overview of e-invoicing in Poland
Poland is undergoing a significant digital transformation in its invoicing landscape, with mandatory e-invoicing for B2B transactions now implemented in phases through the National e-Invoicing System (KSeF 2.0), which launched on February 1, 2026, building upon the existing B2G framework.
B2G e-invoicing
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Since April 2019, all public sector entities are required to receive and process structured e-invoices compliant with the European Standard (EN 16931)
The national e-invoicing platform, PEF (Platforma Elektronicznego Fakturowania), operates within the OpenPeppol network and is used for B2G transactions
Businesses supplying goods or services to public authorities are encouraged to issue structured e-invoices compliant with EN 16931, as this guarantees acceptance.
B2B e-invoicing
E-invoicing is now mandatory for domestic B2B transactions through the National e-Invoicing System (KSeF 2.0), which officially launched on February 1, 2026
The implementation is phased:
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February 1, 2026: Mandatory for large taxpayers (those with annual revenue exceeding PLN 200 million in 2024)
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April 1, 2026: The mandate extends to all other VAT-registered taxpayers
- Grace period for penalties until 31 Dec, 2026
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January 1, 2027: The mandate becomes effective for micro-businesses with monthly sales under PLN 10,000 and invoices under PLN 450
KSeF 1.0 and the MCU (Certificates and Authorizations Module) ceased functioning on February 1, 2026, with businesses required to migrate to the new KSeF 2.0 Taxpayer Application
B2C e-invoicing
Issuing consumer (B2C) invoices through KSeF is optional. Paper or PDF invoices will remain allowed for B2C transactions
If a B2C e-invoice is issued via KSeF upon a consumer's request, it will need to be delivered outside KSeF with a QR code via a method agreed with the consumer
Since January 1, 2026, companies can issue e-invoices with attachments through KSeF, but must submit a notification through the e-Tax Office declaring their intention
E-invoicing standards and networks
Poland has adopted the European e-invoicing standard EN 16931
Peppol BIS Billing 3.0 is utilised as the national Core Invoice Usage Specifications (CIUS) for B2G transactions via the PEF platform
For B2B transactions, the KSeF 2.0 system requires invoices in its proprietary XML format FA(3), which replaced the previous FA(2) structure with the launch of KSeF 2.0 on February 1, 2026
KSeF 2.0 Launch: The production API opened on January 28, 2026, allowing businesses to perform final integration tests before the February 1 mandate took effect
Tax and compliance considerations
E-invoices must comply with Polish VAT laws and record-keeping requirements
The archiving period for electronic invoices in Poland is 5 years. KSeF will also serve as a repository, storing electronic tax documents for up to 10 years
The KSeF system is designed to enhance VAT collection efficiency and provide greater security for commercial transactions
Technical requirements and compliance
KSeF 2.0 Taxpayer Application: This new platform replaced the MCU (Certificates and Authorisations Module) on February 1, 2026, serving as the central hub for managing mandatory technical requirements
Digital Identity Management - The "three pillars" businesses must manage:
- Production Tokens: API keys required for software automation (note: tokens generated for KSeF 1.0 are not compatible with KSeF 2.0)
- Certificates: Digital credentials necessary for secure authentication and critical for the Offline24 mode
- Authorizations: Legal permissions allowing specific employees or accounting firms to act on a company's behalf
Migration Considerations:
- January 25, 2026 was the final date for issuing voluntary e-invoices via KSeF 1.0
- January 28, 2026: KSeF 2.0 API opened in production environment for final testing
- Businesses that missed the January 25 deadline needed to access the new KSeF 2.0 Taxpayer Application immediately on February 1 to manually generate production tokens and re-grant authorisations
Attachment Functionality: Since January 1, 2026, companies can submit invoices with attachments, but must file a notification through the e-Tax Office
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