Poland Publishes New Draft Act on the Use of KSeF
Poland publishes a new draft act on KSeF, clarifying rules on certificates, QR codes, authentication methods, and structured invoice attachments ahead of mandatory e-invoicing.
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:
- Authentication in KSeF
- 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.
