We kindly remind you that the obligation to issue invoices using the KSeF system will be implemented in stages, as follows:
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as of 1 February 2026 – for taxpayers whose sales value (including amount of VAT) exceeded PLN 200 million in 2024,
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as of 1 April 2026 – for all other taxpayers.
The key assumptions of the draft legislation include:
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possibility to issue invoices using cash registers until the end of 2026,
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postponement of the requirement to indicate the KSeF number in payments for e-invoices until the end of 2026,
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the possibility for taxpayers to permanently apply the ‘offline24’ mode (a mode allowing for the issuance of invoices during temporary unavailability of the KSeF system),
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the possibility, until the end of 2026, for micro-entrepreneurs to issue traditional invoices for low-value transactions,
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option to issue e-invoices to consumers,
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the possibility under certain circumstances to transmit invoices with attachments – the attachment will become part of the invoice structure (XML), so it will be standardized to some extent, but at the same time taxpayers will be able to define the content of some fields themselves.
Additionally, a KSeF 2.0 test environment will be available from 1 November 2025, allowing entrepreneurs to familiarise themselves with the new functionalities.
Furthermore, the VAT exemption limit will be raised to PLN 240,000 (the current limit is a maximum net sales value of PLN 200,000 in the previous and current tax year).
The full text of the draft is available here.
The plan of the implementation of the National e-Invoicing System is available here.
Taxpayers can submit additional comments and opinions on the draft until 25 April 2025 by writing to [email protected].
The above reports were kindly shared by Doradztwo Podatkowe from Independent Tax Advisers (Poland). If you need further information, please contact Dorota at: [email protected].
