Regulatory updates - Poland

The updated KSeF 2.0 website features several sections, such as:

• Official Q&A with information on topics like issuing and receiving e-invoices in KSeF, offline modes, QR codes, and technical matters
• Materials tailored for different user groups, including small taxpayers, B2C consumers, accountants, and service providers
• The KSeF 2.0 Manual divided into four sections that address topics such as the implementation of mandatory e-invoicing, issuing and receiving e-invoices, and additional functionalities like attachments, self-billing, and offline modes
• The final schema FA (3) with an Information Brochure for schema FA(3)

A webinar series called "Wednesdays with KSeF" will be held by the Ministry of Finance from September 24, 2025, through mid-December 2025, to support taxpayers as they prepare for the e-invoicing mandate, which is set to begin in 130 days.

Additionally, the API connection to the KSeF 2.0 test environment will become available, on September 30, 2025.

The new project introduces several amendments and provides explanations on, for example:

• KSeF certificate: the draft explicitly mentions two use cases for the certificates 1) authentication in KSeF, and 2) a QR code certyfikat confirming the integrity and authenticity of an invoice. Moreover, taxpayers requesting the certificate will be able to indicate its validity period, up to two years. After two years, the certificate may be renewed.
• QR codes: the draft clarifies that QR codes will be used on structured invoices as well as on invoices issued during offline modes that are used or shared outside of KSeF. In the case of offline modes, two QR codes - offline and certyfikat - will be required.
• Authentication methods: if taxpayers choose to authenticate via token until December 31, 2025, they will not be able to generate the KSeF certificate at the same time. Therefore, to generate a KSeF certificate, the taxpayer will need to use another form of authentication, e.g. qualified electronic seal.
• Attachments to e-invoices: a new definition has been provided; such e-invoices must contain only data as derived from Article 106e (1) of the VAT Act and relate to activities involving complex amounts of data regarding units of measurement and quantities of goods delivered or services performed or net unit prices; otherwise, the right to issue such invoices may be revoked.

Moreover, the FAQ provided by the Ministry of Finance has been updated: Pytania i odpowiedzi - KSeF. The above act regarding the use of KSeF and the act on the exemptions from KSeF are yet to be enacted.

The transition began with the shutdown of the KSeF 1.0 Test environment on September 1, 2025. shutdown of the KSeF 1.0 Test environment on September 1, 2025. Subsequently, the KSeF 2.0 Test environment will open for API testing on September 30, 2025, followed by the Pre‑production (Demo) environment opening on October 15, 2025. Accordingly, testing will not be possible until late September, when the KSeF 2.0 Test environment opens.

As the transition concludes, the KSeF 1.0 Prod environment will be discontinued on January 26, 2026 (ahead of a planned maintenance window from January 26 to 31, 2026), and the KSeF 2.0 Prod environment will go live on February 1, 2026.

Upcoming environments

• September 30, 2025: KSeF 2.0 Test environment launches for open API testing
• October 15, 2025: KSeF 2.0 Pre‑production (Demo) environment opens for API connections
• January 26, 2026: KSeF 1.0 Prod environment discontinued, preceding a planned maintenance window from January 26 to 31, 2026
• February 1, 2026: KSeF 2.0 Prod environment goes live, following the start of the mandate

Additionally, the new Certificates and Permissions (MCU) module will be launched on November 1, 2025, enabling permission management in KSeF and facilitating the submission and download of KSeF certificates. The KSeF Taxpayer App will also be phased in, with availability in the Test environment starting from November 3, 2025, and in the Demo environment from November 15, 2025.

API KSeF 2.0 documentation is available to support integrators in preparing systems for the transition.