Published: 09 October 2026
Poland is approaching another important milestone in the rollout of the National e-Invoice System (KSeF). Many of the changes scheduled for 1 January 2027 were already built into the KSeF 2.0 legislative and implementation framework established before the system became mandatory in 2026. However, since the launch of KSeF 2.0 in February 2026, the Ministry of Finance has issued additional manuals, FAQs and announcements clarifying the 2027 requirements and, in some cases, revising earlier plans.
As 2027 approaches, businesses should therefore review the following changes:
1. KSeF will become mandatory for the remaining smallest taxpayers.
The temporary exemption available to businesses whose monthly gross sales documented by invoices do not exceed PLN 10,000 expires on 31 December 2026. From 1 January 2027, this group will also be required to issue invoices through KSeF, completing the phased mandatory rollout.
2. KSeF invoice numbers will become part of the payment process.
From 1 January 2027, an active VAT taxpayer paying another active VAT taxpayer for relevant KSeF invoices through a payment instrument that allows a payment reference will generally need to provide the KSeF invoice number.
3. Collective Identifiers can be used for payments covering multiple invoices.
Where one payment covers several KSeF invoices, businesses can use a Collective Identifier (zbiorczy identyfikator) instead of listing each KSeF invoice number separately. The identifier is generated through KSeF and can also be handled through commercial financial or accounting systems integrated with the KSeF API.
4. The payment requirement will also apply to the Split Payment Mechanism (MPP).
From January 2027, the KSeF invoice number will form part of the MPP payment message. Where an eligible payment covers several e-invoices, a Collective Identifier can be used instead.
5. The temporary cash-register transition rules will end.
Until 31 December 2026, businesses can continue issuing certain invoices through cash registers outside KSeF. The transitional treatment of fiscal receipts containing the buyer’s NIP and treated as simplified invoices up to PLN 450 also ends at the close of 2026.
6. Token-based authentication will remain available after 2026.
Earlier KSeF 2.0 guidance indicated that token-based authentication would end after 2026, leaving KSeF certificates as the remaining authentication solution. Following consultations held in June 2026, the Ministry decided instead to retain tokens indefinitely, with the relevant regulation expected to be amended accordingly.
7. The Ministry has announced a further extension of the KSeF penalty deferral.
On 16 September 2026, the Ministry announced that KSeF-specific monetary penalties would be deferred until 31 December 2027. The Ministry emphasized that this does not remove the obligation to use KSeF and that the extension still requires legislative amendments.
Together, these developments mean that 2027 represents more than the final expansion of KSeF’s taxpayer scope. It also marks a closer integration between e-invoicing and payment processes, while recent Ministry decisions provide additional continuity for authentication and a longer transitional period for penalties.
