Council of Ministers adopts KSeF 2.0 draft legislation; 1 Feb 2026 B2B e-invoicing
The Polish Council of Ministers adopted on 17 June 2025 a new, second draft version of the KSeF e-invoicing regulations and legislation. The parliamentary and Presidential approval processes will follow with the aim of passing into law in July. This follows the first draft of KSeF 2.0 on 30 May 2025 (see below).
The launch timetable is now:
- Jun 2025:
- new draft legislation (originally due Apr 2025);
- API documentation published with testing phase schedule;
- Finalise FA(3)
- Jul 2025: Parliament approval of final legislation
- end Sept 2025: public testing phase of API for KSeF 2.0; technical documentation, planned system tests and testing environments.
- Nov 2025: invoice issuer certificates available for taxpayers; public testing of mobile app; production environment available
- LAUNCH 1st Feb 2026: large taxpayers, over PLN 200m (2024) pa turnover; and
- LAUNCH 1st Apr 2026: other taxpayers.
- 1st Aug 2026: bank transfer ID references must be added for KSeF
- LAUNCH: Jan 2027
- micro businesses – invoices below PLN450 and less than PLN 10,000 sales per month;
- penalty regime stars for Feb 2026 candidates
- obligation to add KSeF numbers in transfers of invoices between businesses
- ‘Offline24‘ mode now permanent, allowing invoices to be reported following day, including split payments. Any taxpayer issuing in Offline24 will need special approval, available 1 November 2025.
- QR Code now in single format to be added to any paper/PDF produced version of e-invoice;
- 1 Jan 2027 delayed start for:
- Reporting of e-invoices on cash registers;
- Penalty regime for non-compliance with KSeF; and
- Obligation to include KSeF number with payments of e-invoices.
- Option for B2C e-invoicing via KSeF
The latest June 2025 legislation version includes:
- Clarification on domestic invoices issued offline24 is accepted within KSeF;
- Notes on compliance with GDPR requirements
- Confirmation on adding attachments
30 May 2025: Following a round of April public consultations with businesses on the February 2026 launch of mandatory B2B Krajowy System e-Fakturr (KSeF) structured e-invoices, the Ministry of Finance on 30 May 2025 issued:
- Latest draft bill ‘KSeF 2.0 Project‘ and comments
- Two implementing regulations: ID of e-invoice issuers; document authentication code
- Outcomes of April 2025 public consultations
- OSR for the Act; Regulatory Impact Assessments
- New: a deposit system and on VAT settlements, with delayed first settlement dates
- Updated ZAW-FA form for granting or withdrawing permissions
- Natural persons now added to catalogue of buyers
- Changes to the limits for micro-enterprises during the transition period (PLN 10k threshold only; now without limit of PLN 450 per item)
- Relaxation on the voluntary “Offline24” mode requirements for invoices sent outside of KSeF; changes to corrective invoices, too.
- More on the transactions not subject to KSeF obligations
8th May 2025: Ministry of Finance draft logical structure FA(3)
The Ministry of Finance on 8 May published draft KSeF schema for its scheduled 1 February 2026 launch of mandatory B2B e-invoicing. This follows an April round of consultations with taxpayers, accountants and stakeholders. This version, FA(3), will replace the last version FA(2) in January 2026.
Original July 2024 launch scrapped
The original plan was for July 2024, but following a technical audit, it had been concluded that a full architecture rebuild is required. This started at the end of 2024 and is now ongoing. Key changes to the original July 2024 regime:
- New fine regime, with initial soft-launch 1-day delay on live reporting
- Offline mode for emergency QR Code generation for invoices
- Provision to add attachments to e-invoices
- Voluntary use of KSeF to issue B2C invoices
- Limit on VAT deductibility with PIT or CIT taxpayer’s tax ID number.
- Changes to transmission of payment details
Further proposed amendments from the July 2024 launch include:
- Possibility to continue using paper invoices for micro taxpayers if no invoice exceed PLN 450 or monthly total invoicing does not exceed PLN 10,000;
- Likely 1-day grace period on reporting invoices for initial soft landing phase;
- Option for structured attachments for certain supplies (telecoms; electricity, water and similar utilities etc);
- There will be some minor amendments to the SAF-T JPK VAT return, and details will be available in June
- Mobile phone app to be published in April/May;
- Emergency QR Code generation for invoices were service failure and invoices created in ‘offline mode’;
- There will be no phased introduction (which had been suggested), and exempt supplies will be included (had proposed 6-month after taxable supplies);
- Guidance for non-residents with Fixed Establishment (and therefore potential liable to report invoices) will be issued soon
The European Commission granted Polish e-invoicing derogation from the VAT Directive in March 2022.
Check VAT Calc’s global live VAT invoice transaction and e-invoice reporting tracker to see where else real-time submissions of invoices is being implemented.
Read more in our Polish VAT guide.
EU harmonised live transaction VAT reporting proposals
EU VAT in the Digital Age reforms include a channel for harmonised Digital Reporting Requirements (DRR) and Continuous Transaction Controls (CTC) by EU states. This grew from the 2020 Tax Action Plan proposals for a fairer and more efficient EU tax regime.
For invoice VAT calculations, you can check the right VAT calculations on individual or batch transactions with our Advisor and Auditor tool.
Europe e-invoicing and live reporting
