Regulatory updates - Poland

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.

The transition began with the shutdown of the KSeF 1.0 Test environment on September 1, 2025. shutdown of the KSeF 1.0 Test environment on September 1, 2025. Subsequently, the KSeF 2.0 Test environment will open for API testing on September 30, 2025, followed by the Pre‑production (Demo) environment opening on October 15, 2025. Accordingly, testing will not be possible until late September, when the KSeF 2.0 Test environment opens.

As the transition concludes, the KSeF 1.0 Prod environment will be discontinued on January 26, 2026 (ahead of a planned maintenance window from January 26 to 31, 2026), and the KSeF 2.0 Prod environment will go live on February 1, 2026.

Upcoming environments

• September 30, 2025: KSeF 2.0 Test environment launches for open API testing
• October 15, 2025: KSeF 2.0 Pre‑production (Demo) environment opens for API connections
• January 26, 2026: KSeF 1.0 Prod environment discontinued, preceding a planned maintenance window from January 26 to 31, 2026
• February 1, 2026: KSeF 2.0 Prod environment goes live, following the start of the mandate

Additionally, the new Certificates and Permissions (MCU) module will be launched on November 1, 2025, enabling permission management in KSeF and facilitating the submission and download of KSeF certificates. The KSeF Taxpayer App will also be phased in, with availability in the Test environment starting from November 3, 2025, and in the Demo environment from November 15, 2025.

API KSeF 2.0 documentation is available to support integrators in preparing systems for the transition.

Nearly three weeks after Parliament’s approval, the Polish President has signed the final legislation confirming KSeF implementation on February 1, 2026. The act establishes a phased approach for e-invoicing obligations affecting both VAT active and VAT-exempt taxpayers, the timeline is as follows:

• February 1, 2026: large taxpayers whose 2024 sales (including tax) exceeded 200 million PLN (ca. 46 million EUR) must issue e-invoices, while all other taxpayers must receive e-invoices
• April 1, 2026: all remaining taxpayers must issue e-invoices, except for the smallest “digitally excluded” taxpayers
• January 1, 2027: “digitally excluded” taxpayers, with monthly sales not exceeding 10,000 PLN (approx. 2,350 EUR) must issue e-invoices.

The legislation establishes a permanent offline24 mode enabling taxpayers to submit e-invoices to KSeF within one working day from its issuance date. Additionally, it allows for sending structured attachments as part of the e-invoice, based on the schema FA(3), following the approval process through e-Tax Office.

Furthermore, the legislation specifies that KSeF certificates will become available for download from November 1, 2025. These certificates will replace tokens as an authentication method starting January 1, 2027, and will be required to generate QR code nr. II (certyfikat) for use in offline modes.

The final acts regarding the use of KSeF (Art. 106r of VAT Act) and exemptions from KSeF (Art. 106s of VAT Act) are still to be published. As previously announced, the KSeF 2.0 TEST environment will be accessible from September 30, 2025. 

With less than six months until mandatory KSeF implementation, taxpayers should accelerate their preparation efforts to meet the new e-invoicing requirements and position themselves for Poland's upcoming digital transformation.