Regulatory updates - Poland

On September 30, 2025, the Ministry of Finance released the test (integration) environment for the KSeF 2.0 API programming interface.

This open testing phase allows financial and accounting system providers to verify how their software interacts with the National e-Invoice System, ensuring readiness for mandatory compliance. The Ministry of Finance provides technical support for users of the test environment through an online application form.

Entities integrating with the KSeF 2.0 test environment can access technical support from the KSeF 2.0 API team.

As previously reported by Pagero, the KSeF 2.0 API documentation, which enabled integrators to begin preparations for implementation, was published on June 30, 2025. This documentation is available to support integrators in adapting their systems for the test environment.

The next step in the KSeF 2.0 rollout is the release of a pre-production (DEMO) environment, which will be available on October 15, 2025.

The updated KSeF 2.0 website features several sections, such as:

• Official Q&A with information on topics like issuing and receiving e-invoices in KSeF, offline modes, QR codes, and technical matters
• Materials tailored for different user groups, including small taxpayers, B2C consumers, accountants, and service providers
• The KSeF 2.0 Manual divided into four sections that address topics such as the implementation of mandatory e-invoicing, issuing and receiving e-invoices, and additional functionalities like attachments, self-billing, and offline modes
• The final schema FA (3) with an Information Brochure for schema FA(3)

A webinar series called "Wednesdays with KSeF" will be held by the Ministry of Finance from September 24, 2025, through mid-December 2025, to support taxpayers as they prepare for the e-invoicing mandate, which is set to begin in 130 days.

Additionally, the API connection to the KSeF 2.0 test environment will become available, on September 30, 2025.

The new project introduces several amendments and provides explanations on, for example:

• KSeF certificate: the draft explicitly mentions two use cases for the certificates 1) authentication in KSeF, and 2) a QR code certyfikat confirming the integrity and authenticity of an invoice. Moreover, taxpayers requesting the certificate will be able to indicate its validity period, up to two years. After two years, the certificate may be renewed.
• QR codes: the draft clarifies that QR codes will be used on structured invoices as well as on invoices issued during offline modes that are used or shared outside of KSeF. In the case of offline modes, two QR codes - offline and certyfikat - will be required.
• Authentication methods: if taxpayers choose to authenticate via token until December 31, 2025, they will not be able to generate the KSeF certificate at the same time. Therefore, to generate a KSeF certificate, the taxpayer will need to use another form of authentication, e.g. qualified electronic seal.
• Attachments to e-invoices: a new definition has been provided; such e-invoices must contain only data as derived from Article 106e (1) of the VAT Act and relate to activities involving complex amounts of data regarding units of measurement and quantities of goods delivered or services performed or net unit prices; otherwise, the right to issue such invoices may be revoked.

Moreover, the FAQ provided by the Ministry of Finance has been updated: Pytania i odpowiedzi - KSeF. The above act regarding the use of KSeF and the act on the exemptions from KSeF are yet to be enacted.