National E-Invoice System (KSeF) – bill not due until Q2 2025

Dear Sir or Madam,

In response to Parliamentary intervention no 8479, the Ministry of Finance has informed that the bill to amend the National E-Invoicing System (KSeF) Law, taking into account the requests submitted during the public consultation (regarding the bill of November 5, 2024), will not be sent to the Council of Ministers for discussion until the second quarter of 2025.

Consequently, the new legislation on mandatory e-invoicing will be known by the end of June this year.

Delay vs. the previously announced date

Previous announcements by the Ministry of Finance indicated that the bill would be published by the end of the first quarter of 2025, but this deadline was not met. However, the Ministry has emphasized that intensive legislative and technical work is underway and that the bill will be presented to the Council of Ministers in the second quarter of this year. Importantly, a new public consultation has not been ruled out.

Significance of the delay for taxpayers

Although the Ministry of Finance has confirmed that it does not plan to further postpone the effective dates of the mandatory KSeF (February 1 and April 1, 2026), the current delay in the publication of the bill could mean:

  • a shortened vacatio legis and less time to implement the new requirements,
  • the need to re-examine the provisions and adjust the implementation schedules if the final version of the legislation differs from the solutions proposed in the November bill.

KSeF implementation needs to be accelerated – not delayed

Although there is no new bill, the current delay should not be seen as a reason to suspend preparations. On the contrary – the current timeline for the entry into force of the e-invoicing obligation has been explicitly confirmed, and only the time for adapting to the new legislation may be significantly shortened.

We therefore recommend intensifying implementation activities – the appropriate pace of work will minimize operational and organizational risks at a later stage of implementation.

Should you have any questions or doubts, we will be happy to assist you and we encourage you to contact us. Our team will be happy to provide you with tailored support and help you prepare for the implementation of the National e-Invoicing System in your company.

We will keep you informed as soon as any other information is provided by the Ministry of Finance.

 

KONTAKT

Aleksandra Kalinowska Partner, Warsaw

E: aleksandra.kalinowska@pl.Andersen.com
T: +48 22 690 08 70
M: +48 724 440 693

Elżbieta Lis Partner, Katowice

E: elzbieta.lis@pl.Andersen.com
T: +48 32 731 68 58
M: +48 664 948 038

Tomasz Dereszewski Senior Manager, Warsaw

E: tomasz.dereszewski@pl.Andersen.com
T: +48 22 690 08 88

Karol Sitek Senior Manager, Warsaw

E: karol.sitek@pl.Andersen.com
T: +48 22 690 08 88

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