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Poland – Recent Updates and Changes in the KSeF System

On Mar 21, 2024 the Ministry of Finance presented the consultations concerning the introduction of the National E-Invoice System (KSeF). Some important points attract the attention from the presentation.

  • Minister of Finance Andrzej Domański emphasized that they make every effort to announce the new date of mandatory use of KSeF as soon as possible. It has been underlined that when preparing for proposals for changes, they tried to respond to the expectations of the entrepreneurs related to ensuring efficient implementation of the statutory obligation by the head of National Tax Administration Marcin Łoboda. He continued by saying that the obligation to e-Invoice will be introduced at one time for active and VAT-exempt taxpayers.  So a unified deadline for all taxpayers will simplify the process of the implementation. As announced by the Deputy Minister of Finance, by April 3, there will be a draft amendment and technical specifications to be explained but the mandatory date of the postponement will be declared at the beginning of April and May. However, the KSeF will not be in force in 2024.


  • There are deferrals to spare some time for entrepreneurs to adapt their systems to e-Invoice. The mandate to provide the KSeF number in payments will be delayed. An additional delay is also applicable for the invoices issued from the cash register and receipts with the NIP (Tax Identification Number). To ensure a smooth transition, there will be an option to issue e-Invoices offline outside of KSeF with a QR code. Businesses will enter them into the system the next business day. It’s planned to allow the issuance of consumer invoices in KSeF. The consumer will have the opportunity to access the invoice in KSeF by issuing it with a QR code.
  • There will be self-identification of the buyer to issue an invoice by the supplier to KSeF. In this way, the problem of determining whether the issuer must issue an invoice to KSeF for a VAT-exempt buyer will be eliminated. VAT-exempt taxpayers will have to provide either a VAT number (if they are registered) or a NIP on their invoices if there is a commercial purchase.
  • For the taxpayers who have lower volume of invoices will be deemed to be digitally excluded and they will be able to use paper invoices in the initial period of implementing the KSeF. The proposed solution applies to situations where none of the invoices issued by such taxpayers exceeds PLN 450, up to a total value of PLN 10,000 per month. Additionally, no penalties will be imposed during the initial period concerning the mistakes of the businesses at the operation of the system when it becomes mandatory. In May 2024, training for entrepreneurs at tax offices will begin. Interested persons will be able to participate.

In addition to these, according to the latest draft which was published by the Polish Government on 3rd of April, 2024, the consultations have begun on proposed legal changes for mandatory e-invoicing in the National e-Invoice System, running until April 19, 2024. The draft includes adjustments based on entrepreneur feedback. Specific deadlines for implementation will be added later. The Polish Government welcomes any feedback via email until April 19, 2024, with consent for potential publication, except for personal data. More details are available on the Ministry of Finance’s website.


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