Poland: Mandatory B2B Electronic Invoicing as of February 2026

B2B electronic invoicing project in Poland

The Polish Government published in 2021 a draft law on the massification of electronic invoicing in the country. All invoices issued will have to be declared through a central platform called the National Electronic Invoice System - KSeF. All VAT taxpayers with a seat or a fixed establishment in Poland will have to issue electronic invoices. To encourage the use of the new platform, the government has announced, as a tax incentive, the reduction of the VAT refund time by one-third, (40 days instead of 60). In addition, taxpayers may be exempted from filing the JPK_FA file. Companies that wish to do so can use the national KSeF platform, which remains available for voluntary use from January 1, 2022.

The staged implementation will be:

• February 1st, 2026, for large taxpayers (over PLN 200 million per annum),
• April 1st, 2026, for all taxpayers.

With the introduction of the electronic invoice, the government wants to advance in the digitalization of the tax system and be able to benefit from the advantages of its implementation, in the same way that other countries of the Union are already doing, such as Italy, where the B2B electronic invoice is mandatory from 2019.

A detailed timeline has been released for the rollout of KSeF 2.0, the updated version of the system, including technical specifications and testing phases:

• June 2025: Publication of KSeF 2.0 documentation, including:
  • The FA(3) structured invoice schema
  • Updated API documentation
  • Full integration testing schedule
• 30 September 2025: API testing for KSeF 2.0 becomes available.
• November 2025: Test version of the KSeF 2.0 Taxpayer Application will be released.

A grace period for penalties has been introduced. No fines will be imposed for invoice errors until the end of 2026.

Additionally, the obligation to include the KSeF invoice number in bank transfers has been postponed until the end of 2026.

The plan also introduces a new concept called “offline24 mode”, which allows invoices to be issued the following day in specific situations.

National Electronic Invoicing System - KSeF

KSeF is the government's central platform for sending and receiving electronic invoices. Companies must submit all e-invoices to KSeF, where a unique identifier, known as the KSeF ID, will be applied to each invoice.

Invoices will be available for viewing and downloading in their original format or as PDFs on the portal, which will also serve as a repository, storing electronic tax documents for up to 10 years.

Additionally, the platform will issue various acknowledgments, including the timestamped invoice number, rejections, or alerts if invoices cannot be issued due to KSeF's unavailability.

A 'structured invoice' refers to an XML electronic invoice processed through KSeF. For now, structured invoices will coexist with paper and other electronic invoices already in use in the market.

In summary, the functions of the KSeF are:

• Issuing and Receiving e-Invoices.
• Validating invoices.
• ID assignment.
• Archive for 10 years.

Updates on the National e-Invoicing System (KSeF)

The Ministry of Finance in Poland has announced new changes to the KSeF law, along with the release of updated invoice structures. In addition to confirming the new effective dates for the obligation to use e-Invoices, the amendment also addresses key points raised during the public consultation, such as:

• Allowing all taxpayers to voluntarily use the offline mode until the end of 2026.
• Permitting consumer invoices (B2C) to be issued through KSeF (optional).
• Enabling the submission of attachments to invoices in KSeF, regardless of the industry in which the taxpayer operates.
• Allowing taxpayers issuing low-value invoices (up to PLN 450 gross per invoice or PLN 10,000 per month) to continue issuing them in the current form until September 30, 2026.
• Postponing the requirement to provide a KSeF number when making payments for e-Invoices, including payments using split payment mechanism and penalties for non-compliance, until July 31, 2026.

The regulation on the use of the National Electronic Invoice System, dated December 27, 2021, will be repealed and replaced with a new one. The updated regulation will cover QR codes, two-step access to invoices, and internal certification processes.

As for the requirement to provide the KSeF number for structured invoice payments, this will apply to payments made on or after August 1, 2026.

Would you like to know all the details about B2B electronic invoicing in Poland? Watch our webinar with Deloitte and access the answers to all the questions we received during the webinar.

Benefits of the B2B electronic invoice in Poland

Companies that decide to start using e-invoices on a voluntary basis can benefit from some special measures:

• Reduction of VAT declaration from 60 to 40 days.
• Exemption from the JPK_FA file declaration.

These are some of the advantages that the government expects to see with the mass implementation of the B2B invoice.

• Increase control of the tax system while at the same time limiting irregularities in the VAT settlement.
• Contribute to improving the process through easier and faster access to documents.
• Provide greater security to commercial transactions with a standardized invoice.
• Increase state budget revenues due to the supposed increase in VAT collection.
• Improve the competitiveness of the economy and the entrepreneurial mindset, including entrepreneurship.
• Provide the ability to issue e-Invoices using a structured invoice template, with archiving being provided by the tax authority.

EDICOM’s Compliance Service in Poland

EDICOM offers a complete solution for companies established in Poland. EDICOM’s e-invoicing and VAT compliance solutions enable the automation of all B2B and B2G invoicing and tax document declaration processes. The solution can be fully integrated with any ERP, facilitating the generation and issuance of electronic invoices to the KSeF platform, as well as the electronic invoices issued to the Polish Public administration through the PeF central government platform, in compliance with the technical and legal requisites imposed by the Ministry of Finance.

EDICOM’s is also able to automate the issuance of SAF-T files to declare accounting data. EDICOM’s all-in-one solution will help reduce VAT return times, reduce management costs, and guarantees maximal security and confidentiality.

How the EDICOM solution works

• Data Capture: first, our solution integrates with your ERP or accounting system to capture invoice data.
• File Generation: an XML-structured data file is then generated in compliance with regulations.
• Connectivity: a Web Service call required to send the files to the tax authority is made.
• Integration and Reception: The Polish tax authority issues notifications about the status of invoices. These responses are automatically integrated with the client's ERP or accounting system.
• Archiving: XML files of invoices and their associated statuses are stored in our eIDAS-certified electronic archiving system.