Electronic invoicing and e-Reporting in Poland
Poland will implement mandatory B2B electronic invoicing on a phased basis throughout 2026 via the National e-Invoicing System (KSeF). On May 8, 2025, the Ministry of Finance published a draft of the FA(3) scheme, which will replace FA(2) from January 2026. In B2G, public administrations have been receiving electronic invoices since 2019, though submission by suppliers is voluntary.
Characteristics of Electronic Invoicing in Poland
The Polish model is based on clearance for B2B: structured invoices are sent to KSeF for validation and to obtain a unique identifier (KSeF ID). In the B2G context, the exchange is carried out in accordance with UBL 2.1/Peppol BIS 3.0 via the relevant public platform.
Mandatory Use
- B2G: Since 2019, public administrations must be able to receive and manage e-Invoices; sending by suppliers is voluntary.
- B2B: Mandatory in two phases through KSeF:
- February 1, 2026: large taxpayers (>200 million PLN/year).
- April 1, 2026: all other taxpayers.
Invoice Format
- B2B (KSeF): XML structured invoice under FA(2) (current) and transition to FA(3) (draft published in May 2025, applicable from January 2026).
- B2G: UBL 2.1 and Peppol BIS 3.0.
Electronic Signature
The electronic signature is not mandatory for structured invoices sent via KSeF. However, fiscal statements and messages linked to other processes may require qualified signatures as appropriate.
Invoice Archiving
KSeF acts as a repository and allows you to consult and download invoices for 10 years. In addition, taxpayers must archive documentation in accordance with accounting and tax regulations; the general minimum period is 5 years.
Required administrative procedures
- Registration and configuration of credentials for access to KSeF (API or taxpayer application).
- Adaptation of issuance/reception systems to the FA(3) scheme and the KSeF 2.0 API.
- Internal procedures for contingency operation (offline mode) and acknowledgment management.
Fiscal control
KSeF validates each invoice and issues acknowledgments (KSeF ID and timestamp assignment, rejection, unavailability). Continuous control improves traceability and reduces the risk of errors and fraud.
National Electronic Invoicing System - KSeF
KSeF is the central platform for sending and receiving structured invoices. Companies send their invoices to KSeF, which assigns a KSeF ID and makes the documents available for consultation/download (original or PDF). Includes automatic acknowledgments of receipt, rejection, or system unavailability.
FA(3) and KSeF 2.0: milestones and schedule
- May 8, 2025: FA(3) scheme draft.
- June 2025: KSeF 2.0 documentation (FA(3) scheme, updated API, testing schedule).
- September 30, 2025: opening of the KSeF 2.0 API test environment.
- November 2025: pilot version of the KSeF 2.0 Taxpayer Application.
- January 2026: entry into force of the FA(3) scheme (replaces FA(2)).
- February 1 and April 1, 2026: staggered start of mandatory B2B.
Announced regulatory changes
- Voluntary use of offline mode until the end of 2026.
- Optional option to issue B2C invoices through KSeF.
- Inclusion of attachments to invoices in KSeF, without sector restrictions.
- Low value invoices (≤450 PLN per invoice or ≤10,000 PLN/month) may continue to be issued in the current form until September 30, 2026.
- Deferral until July 31, 2026 of the obligation to provide the KSeF number in payments (including split payment) and penalties for non-compliance.
- New regulation (replaces that of 12/27/2021) that will address QR codes, two-step access, and internal certification processes.
- Grace period: no fines for formal errors until the end of 2026.
- Introduction of the "offline24 mode" to issue the invoice the next day in specific cases.
SAF-T reporting in Poland (KAS)
SAF-T (JPK) files are sent in XML to the KAS tax authority. JPK_VAT and, gradually as of 2025, JPK_CIT mandatory. Both must be signed with a qualified electronic signature and archived for 5 years.
JPK_VAT
- Mandatory for all companies as of October 1, 2018.
- Replaces declarations such as VAT-7, VAT-7K, VAT-27, VAT-ZT, VAT-ZZ and VAT-ZD.
- Sending before the 25th of each month.
- Two modalities: JPK_V7M (monthly) and JPK_V7K (quarterly).
JPK_CIT (new)
- Arises from dividing JPK_KR in two: JPK_KR_PD (PIT/CIT ledgers) and JPK_ST_KR (fixed and intangible assets).
- Mandatory on an annual basis, gradual implementation starting January 1, 2025.
- From 12/31/2024: entities with revenue > €50M and tax groups (PGK).
- From 12/31/2025: other CIT and PIT taxpayers obliged to JPK_VAT.
- From 12/31/2026: all other CIT and PIT taxpayers, regardless of size.
Other JPK files on request (audit)
JPK_FA, JPK_FA_RR, JPK_MAG, JPK_KR, JPK_WB, JPK_EWB, JPK_PKPiR, among others, must be able to be generated and submitted electronically when required by the authority.
See frequently asked questions
Below are some of the most frequently asked questions about the electronic invoicing system in Poland.
When do B2B e-invoicing obligations take effect in Poland?
In two phases: February 1, 2026 for large taxpayers (>200 million PLN/year) and April 1, 2026 for all others.
What technical scheme will be used for B2B invoices?
The FA(3) scheme (draft published in May 2025) will replace FA(2) from January 2026.
Is the electronic signature mandatory in KSeF?
For structured invoices sent to KSeF, the signature is not mandatory. Qualified signatures may be required on other reports (e.g., SAF-T).
For how long will invoices be available on KSeF?
KSeF archives invoices for 10 years; additionally, taxpayers must keep their own records in accordance with the regulations (general minimum of 5 years).
What is offline mode and offline24 mode?
The offline mode allows you to issue in contingency without direct connection to KSeF; the offline24 mode allows you to issue the invoice the next day in specific cases. Voluntary use will be possible until the end of 2026.
What SAF-T obligations apply in Poland?
JPK_VAT is monthly (or quarterly in JPK_V7K) and JPK_CIT will be annual from 2025, with phased implementation by taxpayer size. Both are presented in XML, signed, and archived for a minimum of 5 years.
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