Poland's Ministry of Finance Confirms New Timeline for Mandatory E-Invoicing via KSeF

On April 12, 2025, the Polish Ministry of Finance published a press release outlining the updated timeline for the introduction of mandatory e-invoicing through the National e-Invoicing System (KSeF). This announcement followed the publication of Interpellation No. 8479 on March 31 and the release of a draft bill on April 11 introducing significant changes to the upcoming obligations under KSeF.

New Phased Implementation Plan

Mandatory e-invoicing will now be introduced in three main stages, based on the taxpayer's size and profile:

• February 1, 2026 – For large taxpayers with sales exceeding PLN 200 million in 2024 (including VAT).

• April 1, 2026 – For all other entrepreneurs, except those considered digitally excluded.

• January 1, 2027 – For the smallest "digitally excluded" taxpayers, issuing low-value invoices (up to PLN 450) and with monthly sales below PLN 10,000.

Key Milestones in System Rollout

The Ministry also shared a roadmap for the introduction of KSeF 2.0:

• June 2025 – Announcement of KSeF 2.0 functionalities that will apply from February 1, 2026.

• September 30, 2025 – Open API testing begins for integrators and large companies.

• November 1, 2025 – A test version of the KSeF 2.0 Taxpayer Application will be released.

• November 1, 2025 – Entrepreneurs can begin applying for invoice issuer certificates, essential for authentication and issuing invoices during KSeF outages.

Functional and Legal Updates

The draft bill introduces several important changes to the e-invoicing rules:

• Continued possibility to issue invoices via cash registers until end of 2026.

• Deferral of the obligation to include the KSeF number in payment descriptions until end of 2026.

• Permanent availability of the "offline24" mode as an optional feature.

• E-invoicing for B2C (consumer) transactions remains voluntary.

• New support for sending invoice attachments to KSeF — particularly useful for media, telecom, and consolidated invoices.

• Obligation to include the NIP of a local government sub-unit on invoices, requiring changes to the e-invoice schema (addition of the Entity3 element).

• Increase of the VAT exemption threshold from PLN 200,000 to PLN 240,000.

Source Documents

You can find the official documents here:

• Interpellation No. 8479

• Press Release from the Ministry of Finance

• Draft Bill on the RCL Website

Businesses — especially large taxpayers — are encouraged to prepare early for compliance with the new requirements and technical changes coming in 2026.