Will foreign entities registered for VAT in Poland also be required to issue e-invoices?

Yes. The enacted law does not impose any entity restrictions on the ability to issue e-invoices. At the moment, there is no indication that the obligation to use structured invoices, which is effective from 2023, will not be universally applicable.

Will all sales invoices have to be issued as e-invoices, or only those for domestic contractors?

Yes. The enacted law does not impose any restrictions in this regard.

Will it be possible to send invoices (individually or in bulk) without using the API, through an interface accessible to employees?

To date, the Ministry of Finance has only published documentation on how to communicate with the National e-Invoicing System (KSeF) using the API. This means that taxpayers must have their own software capable of using this API. However, there are plans to launch a KSeF platform for issuing, viewing and downloading invoices, as well as an update to the e-Microfirma tool that will allow users to generate e-invoices manually.

Will the invoice issuer be able to download the invoice image from KSeF to print or email to the contractor?

If the recipient has not fully accepted to receive invoices via KSeF, the invoice must be sent via an alternative agreed method, such as e-mail. In this case, it will likely be necessary to send the invoice directly from the issuer's system. At this stage, there are no detailed technical specifications on how to retrieve invoices from KSeF.

How will attachments to invoices, such as energy consumption reports or protocols, be provided to contractors?

The current structured invoice format does not allow attachments to e-invoices. As a result, any necessary attachments will have to be sent outside the system, based on arrangements with individual contractors.

Can the retention period of invoices be extended, and if not, how should they be stored after 10 years?

No. Structured invoices will be stored in the National e-Invoice System (KSeF) for a period of 10 years. If the law requires the taxpayer to store invoices beyond this period, the taxpayer will have to ensure their storage on its own. In addition, it will be necessary to guarantee the authenticity of origin, integrity of content and legibility of invoices.

E-invoicing in Denmark

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Mandatory e-invoicing in Denmark

Denmark was one of the first countries in Europe to introduce mandatory e-invoicing in the public sector (B2G). As early as 2005, all invoices sent to public administration must be issued in a structured format, and since 2019 they must comply with the European standard EN 16931 and be exchanged via NemHandel, using the national OIOUBL 2.1 standard or Peppol BIS Billing 3.0.

In B2B, e-invoicing is not formally mandatory but adoption is accelerating: under the Danish Bookkeeping Act (Bogføringsloven, 2022), almost every company must run a certified digital bookkeeping system able to send and receive structured e-invoices, with the final phase applying from 1 January 2026 (turnover over DKK 300,000) and 1 July 2026 (in-house systems) — and from July 2026 companies issue e-invoices by default unless they opt out. Looking ahead,

Denmark has cancelled the planned OIOUBL 3.0 and will move to a single Peppol-based standard, Nemhandel BIS 4 (aligned with EN 16931 and EU ViDA), with OIOUBL 2.1 phased out around mid-2029. There is no B2C mandate.

E-invoicing standards in Denmark

The e-invoicing system in Denmark is based on structured XML formats compliant with EN 16931 and supports document exchange in both B2G and B2B.

The main components of the system are:

NemHandel - the national e-invoicing infrastructure connecting businesses and public administration.
OIOUBL 2.1 - the national XML standard, required for B2G and widely used in B2B (to be phased out ~2029).
Peppol BIS Billing 3.0 - the international standard, increasingly used in B2B and fully supported by the public sector.
Nemhandel BIS 4 - the upcoming single Peppol-based standard that will replace OIOUBL during the 2028–2029 migration.
Certified private operators - 100+ providers integrating companies with NemHandel and Peppol (Denmark uses no central state platform).

You send invoices and documents to administrations and business partners in Europe directly through PEPPOL, without additional integrations.

Compliance with EU security and interoperability standards (including eIDAS and RODO).

Fewer exceptions, more automation - all PEPPOL countries (e.g., Germany, France, Scandinavia, Benelux) "understand" documents sent via this route.

Peace of mind for CFOs and accountants - because documents are sent through a trusted, controlled channel that complies with EU regulations.

Digitization is no longer about choice - it's about speed and scale. And a well-chosen technology can turn an obstacle into an advantage. That's why it's important to think globally from the start. Even if you're currently operating in just one market, things can change quickly. Regulations evolve, markets open up - and being well prepared at the start avoids chaos and costly adjustments in the future.

Andrzej Mioduski

Management representative for strategic projects at Infinite

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