KSeF – final consultations in progress

The Polish Ministry of Finance has begun the final consultations concerning the implementation of the obligatory National System of Electronic Invoices (KSeF), taking into consideration the specific character of Local Government Units (LCUs) and the concept of electronic invoice attachments.

The Polish Ministry of Finance informed about starting the final consultations concerning the project of legal and business solutions in the scope of implementation of the obligatory KSeF system (notice). These consultations take into consideration the specific nature of Local Government Units and the concept of attachments to electronic invoices.

It is still possible to report comments about KSeF:

• as part of public consultations (namely remarks as to the draft of the act) – by 19 November of this year, to the following address: PT@mf.gov.pl,
• as part of consultations regarding tax business solutions – by 22 November of this year, to the following address: ksef@mf.gov.pl.

The draft of the act has been published in the Public Information Bulletin of the Governmental Legislation Process and can be found on the following website: https://legislacja.rcl.gov.pl/projekt/12391205/katalog/13092624#13092624

KSeF – how did the premises of the system change?

Originally, KSeF was supposed to come into force on 1 January 2022 and apply to all business owners. The system was intended to collect all invoices issued within the territory of Poland, regardless of the sector. KSeF was supposed to act as a central database in which every invoice would be recorded and processed. Originally, companies would be obligated to issue invoices in an electronic form and send them to the system, which would allow tax authorities to have an immediate access to them, reducing the number of errors and tax frauds.

REMEMBER! The National System of Electronic Invoices (KSeF) is an electronic platform created in Poland for centralized processing and archiving of invoices. The system allows companies to issue, receive and store invoices in a structured form. The premise is to increase the transparency of settlements, streamline tax inspections and make the invoicing process faster.

Why was KSeF not introduced within the first scheduled deadline?

The implementation of KSeF involved difficulties and challenges. Due to the complicated structure of the system and the concerns concerning its impact on the functioning of companies, the date of implementation has been postponed several times.

Broad social consultations have been conducted with representatives of various sectors, tax experts and business owner organizations. Results of the consultations indicated a need to introduce modifications to improve the use of the KSeF system.

Also check: Act on the National System of Electronic Invoices signed by the President

What are the changes compared to the first version of KSeF?

The user interface was simplified, additional options were added for integration with the existing accounting systems as well as aid mechanisms and training for business owners. There has also been a plan to introduce a transitional period during which companies could voluntarily use KSeF and gradually adjust to the new requirements.

As part of further improvements, the option to send attachments to invoices was added, which is particularly helpful in situations requiring additional explanations and proofs of authenticity. The new version of Schema allows providing more detailed descriptions of goods and services. The data validation mechanisms have also been improved. Moreover, a KSeF mobile app was introduced to allow issuing invoices and their corrections directly on the phone.

You may also be interested in: Have the efforts connected with KSeF been a waste of time?

What is the starting point of the final consultations on KSeF and when will the system become effective?

As the result of the recent consultations, the Polish Ministry of Finance proposed legal solutions that will simplify the implementation and application of KSeF, particularly during the first period after the introduction of the system – along with its gradual implementation. What are the newest premises?

The obligatory use of the system for business owners the sales value of which in 2025 exceeds PLN 200 million will be postponed to 1 February 2026. The date for the rest of business owners is scheduled for 1 April 2026.

Some solutions are planned to be postponed by another six months, i.e. postponed from 1 January to 31 July 2026 – for example, the requirement to specify the KSeF number in payments for electronic invoices or invoices issued with cash register devices.

The new solutions are intended to facilitate the introduction of KSeF and improve its availability to all taxpayers.

Is KSeF a challenge for your company?
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Author: Joanna Kargulewicz, Accounting Manager, e-mail: biuro@mddp-outsourcing.pl, mob: (22) 351 13 45