KSeF: A new era of e-Invoicing – key changes and implementation schedule
KSeF Regulation in consultation. What does it establish?
The draft regulation of August 26, 2025 is key to understanding future obligations. It specifies the types of authorizations for using the KSeF, the methods for granting and withdrawing them, and the methods for authenticating within the system. Technical requirements for labelling structured invoices, both those sent through the KSeF and those made available outside of it (e.g., in the event of a failure), are also important. The regulation also specifies the scope of data required to report the intention to issue invoices with attachments.
New permissions and authentication rules
The introduced regulations are intended to expand and streamline access to the system in terms of:
- Permissions – New features include granting and revoking access to KSeF for other people within the company. Additionally, for the first time, the system will enable the issuance of VAT RR invoices and VAT RR correction invoices. The list of entities eligible for system permissions will also be expanded.
- Credentials – The procedure is intended to become simpler and more modern. Identity verification will be based on electronic identification methods such as trusted profiles, qualified certificates, and KSeF certificates. KSeF certificates will be valid for two years and can be easily renewed.
Issuing e-invoices, attachments and technical requirements
The regulation also clarifies the rules for working with e-invoices in various scenarios:
- Offline mode – invoices issued outside the system (e.g. in the event of a failure) will have to contain a verification code (QR or a string of numbers) and the word “OFFLINE”.
- Invoices shared in KSeF and used outside the system will in turn be marked with a verification code and KSeF number.
- Invoices with attachments – the Ministry of Finance will allow the attachment of attachments to invoices in the Tax Office. To use this option, it will be necessary to notify the taxpayer in advance via the e-Tax Office. This significant improvement is intended to help maintain the consistency of documents in one place.
KSeF implementation schedule – key dates
The Ministry of Finance has released a detailed schedule for the work, testing, and launch of key modules. It is worth paying particular attention to the mandatory e-invoicing launch dates:
| Date (Month/Year) | Event | Comments |
|---|---|---|
| October 15, 2025 | KSeF 2.0 API released in pre-production environment | Pre-production version (DEMO) |
November 1, 2025 |
Launch of the Certificates and Authorizations Module (MCU) |
Possibility to apply for a KSeF certificate |
November 15, 2025 |
Providing the Taxpayer Application KSeF 2.0 |
Pre-production version (DEMO) |
| January 1, 2026 | Launch of the module for reporting invoices with attachments on e-Tax Office |
Applies to invoices with attachments |
February 1, 2026 |
KSeF 2.0 Launch – Mandatory Start | For large entrepreneurs and invoice recipients (whose sales value including tax amount exceeded PLN 200 million in 2024) |
April 1, 2026 |
KSeF 2.0 Compulsory |
For other entrepreneurs |
| January 1, 2027 | Mandatory KSeF 2.0 for previously exempt entrepreneurs |
(for those who issue invoices with a total value not exceeding PLN 10,000 gross per month) |
KSeF in 2027, or the low-limit trap
The only group that has been given a few extra months to adapt are micro-entrepreneurs with a monthly turnover below PLN 10,000, who can breathe a sigh of relief until the end of 2026. However, this low threshold is causing serious controversy in the business community.
There are voices that this limit is too low and does not reflect the actual realities of running even the smallest business activity. Despite calls to raise the threshold (Interpellation No. 12046), the Ministry of Finance upheld the decision to leave the sales limit entitling to issue invoices outside the KSeF at PLN 10,000.
Do not wait until the last minute – prepare your company for KSeF today!
The approaching mandatory e-invoicing deadline and the need to adapt many company processes mean that time is of the essence. Regardless of your company's size, KSeF will have a real impact on your accounting and IT processes. To avoid operational paralysis, errors, and potential penalties, early implementation planning and employee training are essential. Ensure peace of mind and a smooth transition into the e-invoicing era.
Take advantage of our service – KSeF Consulting – to make your business fully ready for the KSeF revolution!
