The Minister of Finance has amended the regulation on data in tax returns and records for goods and services tax, delaying the implementation dates for adapting JPK_VAT to the declaration, in line with the postponed mandatory KSeF.
From February 1, 2026, to July 31, 2026, taxpayers will not need to show the KSeF invoice number in sales records, and the requirement to include data from simplified invoices in JPK_VAT with the declaration is postponed until the end of July 2026. Consequently, the regulation’s effective date is now February 1, 2026.
The mandatory KSeF deadline is postponed to February 1, 2026, according to an act published on June 10, 2024. This act marks the first step in legislative work on the KSeF system, with further proposals to simplify obligations and phase in the mandatory KSeF:
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February 1, 2026, for entrepreneurs with sales over PLN 200 million in 2025.
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April 1, 2026, for other entrepreneurs.
Consultations on Mandatory KSeF in Poland
On July 18, 2024, the Ministry of Finance and the National Revenue Administration (KAS) held a consultation meeting on the National e-Invoice System (KSeF). Ministry representatives reviewed the pre-consultations on easing the conditions for mandatory KSeF and discussed further simplifications, including deferrals and a phased implementation. Experts proposed business solutions such as updating the e-invoice structure and implementing attachments.
Jarosław Neneman, Undersecretary of State at the Ministry of Finance, emphasized the importance of reliable consultations due to the diverse entities affected by KSeF. The meeting included 80 in-person attendees and over 3,300 online participants.
The legislative process for KSeF has two stages. The first stage delayed the obligation to February 1, 2026, and the second stage will introduce mandatory KSeF in phases: starting February 1, 2026, for large businesses and April 1, 2026, for others. Discussions included simplifying the system, allowing offline mode during the transition, and issuing invoices up to PLN 450 outside KSeF.
Anna Mytyk, Deputy Director of the Goods and Services Tax Department, highlighted the challenge of implementing KSeF and the need for optimal solutions.
Participants discussed the mandatory or optional nature of consumer invoices and confirmed some deferrals, such as penalty deferrals for non-compliance.
New functionalities were presented, including sending invoice attachments, modifying the e-invoice structure, and aligning KSeF environments. Krzysztof Rogowski, Director of the KAS Analysis Department, stressed the importance of a stable implementation process. These include:
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Allowing industries that issue invoices with complex data to send invoice attachments.
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Modifying the logical structure of e-invoices, particularly regarding payment deadline rules.
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Standardizing KSeF environments by fully implementing “business” functionalities, allowing invoices to be issued in KSeF’s target model without altering taxpayer obligations.
During the meeting, ministry representatives answered participant questions, with frequently asked questions to be posted on the podatki.gov.pl website.
