The KSeF legislative process is in its final stages
Dear Sirs,
On 9 July 2025, the first reading of a draft law implementing mandatory KSeF (Sejm print no. 1407) took place in the Sejm, after which the draft was referred to the Public Finance Committee (Sejm print no. 1475).
The next legislative step will be the report of the Public Finance Committee in this regard, which is likely to take place during the Sejm session between 22 and 25 July 2025. The above confirms a significant acceleration in the work on these regulations in order to complete the legislative process in this area at the turn of July and August.
What is already in place and what are we still waiting for?
At this point, virtually all documents necessary for very advanced implementation work are available, in particular:
- The aforementioned draft provisions of the act implementing KSeF,
- Draft executive regulations on the use of KSeF and exemptions from the obligation to issue invoices using KSeF,
- The draft structured invoice FA(3) available on ePUAP, which will form the basis for issuing structured invoices,
- API documentation with relevant explanations, which is an important element for the work of IT solution providers.
With the exception of the API documentation, the above documents are still at the draft stage, but as work progresses, subsequent versions are likely to bring only cosmetic changes and there are no grounds for expecting any major changes. At the same time, we are still awaiting:
- Clarifications from the Ministry of Finance, which are intended to provide taxpayers with guidance on questionable issues, such as the date of issue of an invoice in the light of Article 106nda of the amended Act. The Ministry has not indicated a planned date for the publication of these clarifications. Work on them is ongoing.
- Open API tests – technical documentation in this regard has already been made available, and open tests are planned for September.
- Making available invoice issuer certificates that will allow authentication in the system and offline invoicing. This step is planned for November 2025.
- Updating the Taxpayer Application to version KSeF 2.0. This step is also planned for November 2025.
Last moment to start implementation activities for KSeF
The above clearly indicates that the ministry has no intention of further postponing the mandatory KSeF. This means that from 1 February 2026, all taxpayers will have to be ready for KSeF on the purchasing side, and the largest ones also on the sales side.
This leaves just over half a year to implement the largest digitalisation revolution in VAT, which affects one of the most important processes in an organisation.
There is no point in delaying. This cannot be done in a month.
If you have any doubts, please do not hesitate to contact us.
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
