Published: December 2025
The Ministry of Finance and Economy has released four implementing regulations that set out the operational, technical, and reporting rules for the National e-Invoice System (KSeF). The package clarifies exemption cases, simplified invoice requirements, system-usage procedures, and adjustments to JPK_VAT reporting.
1. Regulation on Cases Exempt from Structured Invoicing
Several types of transactions will fall outside the obligation to issue structured invoices in KSeF. These include motorway toll services documented with receipts containing a NIP, passenger transport services where tickets act as invoices, sector-specific aviation control services, and certain financial or insurance documents that cannot technically be issued through KSeF. The regulation also introduces limited exceptions for self-billing when the buyer or seller is a foreign entity without a Polish Tax Identification Number. In some intra-Community scenarios, however, a foreign buyer identified with an EU VAT number may still issue self-billing invoices in KSeF.
2. Regulation Amending the Rules for Issuing Simplified Invoices
From 1 February 2026, simplified invoices issued via KSeF must include the seller’s Tax Identification Number (NIP). For simplified invoices issued outside KSeF—particularly B2C transactions—the existing rule remains unchanged: the seller is not required to include their NIP. Where applicable, the buyer’s NIP may also appear on the simplified invoice. These adjustments align simplified invoicing with the structured e-invoicing mandate.
3. Regulation on the Use of the National e-Invoice System
This regulation defines how taxpayers will operate within KSeF. It covers authorisation rules and the ZAW-FA notification template, authentication procedures, access parameters for retrieving invoices, methods for marking invoices to ensure authenticity and integrity, and the technical workflow for issuing invoices with attachments. The detailed requirements reflect the Ministry’s technical documentation provided to system integrators.
4. Regulation Amending the JPK_VAT Scope of Data
To align JPK_VAT with structured invoicing, taxpayers will be required to include the KSeF invoice number in both sales and purchase records. New designations—OFF for invoices not yet assigned a KSeF number at the time of filing, BFK for electronic or paper invoices, and DI for non-invoice evidence—will distinguish document types submitted outside KSeF. Offline24 invoices that receive a KSeF identifier after JPK submission will require correction. The updated structure applies to settlement periods beginning 1 February 2026, and the Ministry notes that tools such as e-mikrofirma will automate much of the data import process. Penalties for incorrect JPK filings remain non-automatic and apply only if taxpayers fail to correct errors after receiving a request from the tax office.
Together, these four regulations establish the core legal and technical foundation for Poland’s transition to mandatory structured e-invoicing in 2026. They clearly define which transactions must use KSeF and which are exempt, standardise the requirements for simplified invoices issued inside and outside the system, and set out the operational framework governing authorisations, authentication, and invoice integrity. At the same time, the accompanying amendments to JPK_VAT ensure that structured invoice data—particularly the KSeF identifier—is fully integrated into monthly VAT reporting.
