Poland e-Invoicing: mandatory start is almost here (with a grace period)

Polish VAT taxpayers will be required to issue electronic invoices through KSeF, the central e-invoicing platform operated by the Polish tax authorities. Once issued, invoices must be submitted to KSeF immediately, or at the latest by the next working day.

After successful validation by the system, a unique KSeF number is assigned to the invoice. The invoice then becomes automatically available in the customer’s KSeF account, where it can be downloaded. In principle, Polish companies are not required to archive invoices themselves, as KSeF stores all invoices for 10 years.

Phased introduction of the KSeF obligation

The obligation to issue invoices via KSeF will be introduced in three stages:

1. From February 1, 2026
   Applies to taxpayers whose gross sales in 2024 exceeded PLN 200 million.
2. From April 1, 2026
   Extended to all other VAT taxpayers, except the smallest taxpayers with gross sales below PLN 10,000 per month.
3. From January 1, 2027
   The smallest taxpayers will also be required to use KSeF.

Receiving invoices: obligation starts earlier

An important point that is often overlooked: All invoices issued via KSeF after February 1, 2026 are legally considered delivered. This means that all Polish VAT taxpayers, even those not yet required to issue e-invoices themselves, must be able to receive and monitor invoices in KSeF as of that date.

Grace period for penalties, but not for readiness

The Polish Ministry of Finance has announced a grace period: no financial penalties or formal sanctions will apply for non-compliance with the KSeF obligation until January 1, 2027. This is intended to give businesses time to adjust and address potential system challenges.

However, this does not remove the requirement to be technically ready to receive e-invoices from February 1, 2026.

Why delaying implementation can still cause problems

While the grace period may seem like a reason to postpone implementation, doing so can create practical and compliance challenges.

For example:

• In SAF-T reporting, the date of receipt of purchase invoices must be reported, and this date is the KSeF receipt date.
• The assigned KSeF number must also be included in SAF-T filings.
• Without KSeF in place, capturing this data for domestic purchases becomes complex and error-prone.
  

From a customer perspective, delays may also increase the burden when claiming VAT deductions. Invoices issued outside KSeF require additional proof, while invoices processed through KSeF are already fully visible to the Polish tax authorities.

Our view

Polish businesses can technically make use of the grace period. But in practice, waiting offers little benefit and introduces avoidable risks.

Preparing your systems and processes now ensures you can both receive and issue e-invoices smoothly, avoid reporting issues, and stay in control as Poland moves fully into the KSeF era.

Our solution

Of course, our eInvoicing solution NORA fully supports the Polish KSeF requirements. Whether you are preparing for mandatory eInvoicing, setting up invoice reception, or aligning your SAF-T processes, we’re happy to think along with you. Do you have questions about the new legislation or its practical implementation?

Let’s talk. We’re here to help you move forward.