KSeF consultations in Poland: summary and future plans

On 18 July 2024, the MF and the National Tax Administration held another consultation meeting on the KSeF, during which representatives of the Ministry of Finance summarised the pre-consultation of solutions to date liberalising the terms of the mandatory KSeF.

The meeting focused on the direction of further actions, including the confirmation of the timeline. The Ministry's experts presented proposed solutions, i.e. replacing the KSeF environment with a target environment, implementing attachments and updating the e-invoice structure.

Ministry representatives recalled that the legislative process is divided into two stages. The first stage was the postponement of the compulsory implementation of the KSeF to 1 February 2026. The discussions concerned Stage II of the legislative work, under which the ministry will propose a phased entry into force of the mandatory use of KSeF:

• 1 February 2026 for entrepreneurs whose turnover (including tax) exceeded (in 2025) 200 million PLN,
• 1 April 2026 for the remaining entrepreneurs.

By the the end of 2024, the technical environment, and updated regulations for the launch of KSeF are to be prepared. Until then, public consultations on individual areas related to KSeF will be held. A "road map" of implementation of new functionalities in individual environments will be also discussed.

New FA(3) schema is currently in development. Its structure is likely to be published and consulted in September this year and is planned to be implemented at the end of 2024. The ministry assured, that the changes will be kept to a minimum. 

In addition, a completely new structure for attachments will be published in a similar timeframe.

During the meeting, the Ministry's experts also summarised the legal and business directions for simplifying the system, including the use of an offline mode during the transition period and the possibility of invoicing up to PLN 450 outside the KSeF.

The final form of the legislation, which is also expected after the summer, is still under discussion. In particular, issues relating to consumer invoices were raised, and it is still unclear whether such invoices should be sent to KSeF on an optional or mandatory basis. The meeting confirmed the legitimacy of maintaining the postponement of certain KSeF solutions, such as the postponement of penalties for non-application of the KSeF.

There’s more you should know about e-invoicing in Poland – visit our dedicated website and stay up to date with the new and upcoming regulations.