New KSeF legislation already published
Dear Sir or Madam,
On Friday 11 April 2025, new legislation on the National e-Invoicing System (KSeF), the so-called KSeF 2.0, was published. These are long-awaited provisions that define the main principles of the system and confirm the solutions reached during the public consultations.
Major changes – what needs to be known
As previously announced, the following issues have been resolved:
- it has been confirmed that the mandatory KSeF will come into force:
- on 1 February 2026 – for taxpayers with a turnover exceeding PLN 200 million and
- on 1 April 2026 – for other taxpayers.
- it has been established that the PLN 200 million threshold will be determined on the basis of data for 2024,
- a regulation has been introduced for the so-called offline mode, i.e. the possibility of issuing invoices in accordance with the schema but outside the KSeF, with the obligation to send them to the system on the next working day at the latest. Importantly, this mode will not be limited in time (despite earlier announcements suggesting that this will be a transitional solution);
- the voluntary nature of issuing e-invoices to consumers (B2C) has been maintained;
- an attachment to the regulations has been introduced, which will become an integral part of the FA(3) schema;
- an obligation to indicate the TIN of the subordinate unit of the TSU has been introduced (in the Entity3 field).
Transitional period by the end of 2026
In order to ensure a smooth transition to the mandatory KSeF, there will be a transitional period until the end of 2026, during which a number of simplifications will be in force. During this period, taxpayers will be offered additional facilitations, such as:
- continued possibility to issue invoices using cash registers;
- no obligation to include the KSeF number in transfers (also under SPM);
- no sanctions for errors made when invoicing under the KSeF.
Additional changes
In addition to the changes specifically announced by the Ministry of Finance, there are also new issues that will affect the way taxpayers operate in and out of the KSeF system, including:
- an increase in the VAT exemption limit from PLN 200,000 to PLN 240,000,
- the possibility of downloading the invoice issuer certificate earlier from 1 November 2025,
- the availability of the KSeF 2.0 test environment – also from 1 November 2025.
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The above information is an important message, especially for those companies that have already prepared their systems to operate under the previous assumptions. The new regulations are not revolutionary, and much of the work done to date is likely to remain valid. However, it may be prudent to review the solutions already implemented in light of the new technical requirements. It also signals that there is no room for further delay – for larger companies, this is the last moment to start implementation.
We are closely analyzing the new legislation and the MoF’s comments, which are usually made as soon as they are published. As new information becomes available – we will promptly provide a summary.
KONTAKT
E: aleksandra.kalinowska@pl.Andersen.com
T: +48 22 690 08 70
M: +48 724 440 693
E: elzbieta.lis@pl.Andersen.com
T: +48 32 731 68 58
M: +48 664 948 038
