On August 5, 2025, the Polish Sejm concluded its approval of the draft KSeF e-invoicing legislation by endorsing amendments proposed by the Senate. The legislation is now awaiting presidential approval, which is anticipated shortly.
The implementation of the first phase of the Polish e-invoicing mandate is scheduled to begin on February 1, 2026, targeting larger businesses initially, with smaller companies required to comply by April 1, 2026.
Timetable for the KSeF E-Invoicing Launch
- June 2025: The KSeF 2.0 API documentation will be released, introducing the new FA(3) format and allowing integrators to prepare for system implementation within a testing environment.
- July 2025: Parliamentary approval of the new draft legislation is secured, followed by the presidential signing of the finalized legislation.
- End of September 2025: A public testing phase for the KSeF 2.0 API will commence, which includes the release of technical documentation, planned system tests, and the development of testing environments.
- November 2025: Invoice issuer certificates will become available for taxpayers, alongside public testing of the mobile application. The production environment will also be accessible during this time.
- February 1, 2026: The e-invoicing mandate will launch for large taxpayers with an annual turnover exceeding PLN 200 million as of 2024.
- April 1, 2026: The mandate will be extended to include all other taxpayers.
- August 1, 2026: Implementation of mandatory bank transfer ID references will take effect for KSeF transactions.
- January 2027: Micro businesses with invoices below PLN 450 and monthly sales under PLN 10,000 will be required to comply with the e-invoicing framework.
- As of February 2026, a penalty regime for non-compliance with KSeF obligations will be introduced, which includes the requirement for businesses to provide KSeF numbers on invoice transfers.
Additionally, the "Offline24" mode will become a permanent feature, allowing invoices to be reported the following day. This mode includes provisions for split payments, and taxpayers wishing to utilize Offline24 will need special approval, available starting November 1, 2025. Importantly, invoices issued in "Offline24" mode can only be delivered to buyers outside the KSeF framework if the buyer is not a participant in KSeF (e.g., foreign entities or consumers).
To ensure standardization, a QR code format will be mandated for inclusion on all printed or PDF versions of e-invoices.
As Poland moves forward with the KSeF e-invoicing mandate, businesses must prepare for compliance to facilitate a smoother transition into this digital invoicing landscape.
How Can KGT Support You?
KGT has created an SAP-integrated SAF-T add-on solution for Poland, featuring outbound and inbound functionalities to meet tax reporting requirements. This add-on includes a data extractor and a cockpit for generating periodic e-invoicing files in the legal format and controls before submission. When SAP DRC launched the Polish e-invoicing solution as part of its e-document offerings, KGT emerged as a leading consultancy firm for SAP DRC and tax services. Recognized as an SAP DRC partner for Polish e-invoicing services, KGT is one of SAP's recommended implementation partners for this solution. We provide comprehensive support, including installation, configuration, customization, and training, to help you maximize the long-term value of your SAP DRC investment.
KGT is an SAP partner for PE services and an SAP Build partner, and to become an SAP partner, strict due diligence requirements must be met, including having certified SAP consultants. You can find us at: https://partnerfinder.sap.com/profile/0001925409
