Poland Releases Final Executive Acts Completing KSeF Framework

The Polish Ministry of Finance and Economy has signed the remaining executive acts, completing the legal framework for mandatory e-invoicing via KSeF. With these acts finalized, Poland has closed the legislative phase of its KSeF rollout.

Act on Exemptions from KSeF

Published in the Official Journal on December 9, 2026, this act defines cases where invoices are not required to be issued through KSeF. These include:

• Motorway tolls, where a receipt with a NIP is treated as an invoice
• Passenger transport, where tickets are treated as invoices
• Air traffic control and supervision charges
• Financial and insurance services exempt from VAT, issued as simplified invoices
• Self-billing by a foreign purchaser without a NIP number
• Self-billing by a purchaser authorized by a foreign taxpayer without a NIP number

Act on the Use of KSeF

This act, currently awaiting publication in the Official Journal, clarifies technical and operational rules, including:

• Authorization and authentication methods, such as KSeF certificates and permission management, including the ZAW-FA form
• Data requirements for anonymized access to invoices without additional authentication
• QR code rules for sharing and using invoices outside KSeF in both online and offline scenarios
• Procedures and technical standards for structured attachments under the FA(3) schema

Amendment on Issuing Invoices in KSeF

Published in the Official Journal on December 10, 2026, this amendment:

• Standardizes simplified invoice rules in KSeF for VAT-exempt taxpayers and transactions
• Requires simplified invoices issued in KSeF to include the issuer’s NIP from February 1, 2026
• Confirms that invoices issued outside KSeF are not subject to this NIP requirement
• Requires inclusion of the purchaser’s NIP, where applicable

Amendment to JPK_VAT Rules

Still pending publication, this amendment updates JPK_VAT reporting to reflect mandatory e-invoicing. JPK_VAT must include the KSeF invoice number, regardless of whether the invoice was issued or transmitted online or offline, based on its status at the time of filing.

With these executive acts completed, the KSeF legislative framework is now fully in place. Taxpayers have approximately 45 days remaining before the mandate begins on February 1, 2026, when:

• Large taxpayers must start issuing e-invoices, and
• All taxpayers must be able to receive e-invoices through KSeF.