Poland Publishes New Draft Act on the Use of KSeF

On September 1, 2025, the Polish Ministry of Finance published a new draft act clarifying and amending rules related to the use of the National E-Invoicing System (KSeF). The draft provides additional guidance on certificates, authentication, QR codes, and structured attachments.

Key Clarifications in the Draft Act

KSeF Certificates

• Certificates will serve two purposes:
  1. Authentication in KSeF
  2. Generation of a QR code (certyfikat) confirming invoice integrity and authenticity
• Taxpayers may define the validity period of a certificate, up to two years, with the option to renew after expiry.

QR Codes

• QR codes will be required on structured invoices and on invoices issued in offline modes that are shared outside KSeF.
• In offline scenarios, two QR codes will be mandatory:
  • Offline QR code
  • Certyfikat QR code

Authentication Methods

• Taxpayers authenticating via token until December 31, 2025, will not be able to generate a KSeF certificate at the same time.
• To generate a certificate, an alternative authentication method must be used, such as a qualified electronic seal.

Attachments to E-Invoices

• A new definition limits the use of structured attachments to invoices containing data aligned with Article 106e(1) of the VAT Act.
• Attachments are intended only for transactions involving complex data, such as detailed quantities, units of measure, or net unit prices.
• Misuse of attachments may result in the revocation of the right to issue such invoices.

In parallel, the Ministry of Finance has updated its official KSeF FAQ (Pytania i odpowiedzi – KSeF). The draft act on KSeF usage and the related act on KSeF exemptions are still pending enactment.