New regulations for Poland’s National E-Invoicing System (KSeF) for 2026. Key changes for businesses

The National E-Invoicing System (KSeF) in Poland is entering a new phase – the Polish Minister of Finance and Economy has signed four key executive regulations that specify the functioning of KSeF. The documents explain, among other things, when there is no obligation to issue structured invoices in KSeF, how simplified invoices will change, and what the rules for using the system will be (including authorisations and ZAW-FA). The new regulations also specify how to report invoices in JPK_VAT with a declaration from 1 February 2026. For entrepreneurs, these regulations are as important as the act itself, as they determine how it will work in practice.

In this article, we discuss in detail the four implementing regulations for the National E-Invoicing System (KSeF) in Poland, their impact on businesses, examples of exemptions, new obligations, and what needs to be taken into account in accounting processes and ERP systems.

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New regulations for Poland’s National E-Invoicing System (KSeF) for 2026. Key changes for businesses

KSeF is entering a new phase – the Minister of Finance and Economy has signed four key executive regulations that specify the functioning of the National E-Invoicing System (KSeF). The documents explain, among other things, when there is no obligation to issue structured invoices in KSeF, how simplified invoices will change, and what the rules for using the system will be (including authorisations and ZAW-FA). The new regulations also specify how to report invoices in JPK_VAT with a declaration from 1 February 2026. For entrepreneurs, these regulations are as important as the act itself, as they determine how it will work in practice.

In this article, we discuss in detail the four implementing regulations for KSeF, their impact on businesses, examples of exemptions, new obligations, and what needs to be taken into account in accounting processes and ERP systems.

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The National E-Invoicing System (KSeF)in Poland – why are implementing regulations so important for businesses?

The implementation of the National E-Invoicing System (KSeF) in Poland is not just a change in the way invoices are issued. In practice, it means a restructuring of sales, accounting, document circulation and system integration processes, as well as a new way of reporting in JPK. The act sets out the obligations and framework, but it is the implementing regulations that answer the questions:

• when KSeF will not be mandatory,
• what specific data must appear on documents,
• what KSeF authorisations and authentication methods will look like,
• how to handle invoices with attachments,
• how to report invoices from KSeF and outside KSeF in JPK_VAT with a declaration.

The signing of four implementing regulations is a step that finalises the organisational and technical aspects of the mandatory E-Invoicing System (KSeF) – and at the same time indicates areas that may be particularly sensitive for companies: exceptions, simplified invoices, self-invoicing, offline modes and reporting.

getsix® offers comprehensive e-invoicing solutions tailored to the size of your company and the specifics of your industry. Full accounting in Poland, streamlining of financial processes and preparation for KSeF 2.0 are part of our comprehensive service – please contact us for details.

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National E-Invoicing System (KSeF) in Poland 2026 – what regulations has the Polish Minister of Finance and Economy signed?

Four executive acts concerning KSeF have been signed:

1. Regulation of the Minister of Finance and Economy of 7 December 2025 on cases in which there is no obligation to issue structured invoices (Journal of Laws, item 1740).
2. Regulation of the Minister of Finance and Economy of 7 December 2025 amending the regulation on issuing invoices (Journal of Laws, item 1742).
3. Regulation of the Minister of Finance and Economy of 12 December 2025 on the use of the National e-Invoice System (Journal of Laws, item 1815).
4. Regulation of the Minister of Finance and Economy of 12 December 2025 amending the regulation amending the regulation on the detailed scope of data contained in tax returns and records in the field of goods and services tax (Journal of Laws 2025, item 1800).

In the following sections, we discuss each of them, showing what they mean for entrepreneurs.

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Exemptions from the obligation to issue structured invoices (Journal of Laws, item 1740)

National E-Invoicing System (KSeF) in Poland and situations where a structured invoice is not required

The first regulation (Journal of Laws, item 1740) specifies cases in which there is no obligation to issue structured invoices in KSeF. The key reason for the exemptions is the technical limitations of the structured invoice scheme – invoices in KSeF are issued according to the template in Article 106gb(8) of the VAT Act, and certain documents (e.g. single-use tickets or specific financial documents) have a narrower scope of data permitted by law and cannot be directly reproduced in KSeF.

The regulation is specific in nature – it does not abolish the KSeF obligation, but indicates certain types of activities that may be documented differently.

List of exemptions – when is it not necessary to issue an invoice in the system?

The regulation covers six basic areas:

1) KSeF and toll motorway journeys

There is no obligation to issue structured invoices in KSeF in the case of:

• the provision of toll motorway travel services,
• documented by invoices containing a narrower scope of data than that specified in Article 106e of the VAT Act (e.g. a receipt with a tax identification number recognised as an invoice).

This is important for companies with vehicle fleets, logistics and transport, which collect large quantities of such documents.

2) KSeF and passenger transport documented by tickets

The exemption applies to passenger transport services if they are documented by tickets recognised as invoices. This refers to transport over any distance, including:

• standard gauge railways,
• rolling stock,
• seagoing vessels,
• inland and coastal waterways,
• ferries,
• aircraft and helicopters.

In practice, this means that invoices issued in the form of a single ticket (recognised as invoices) remain outside National E-Invoicing System (KSeF) as documents with a narrower scope of data.

3) KSeF and air traffic control and supervision (route charges)

The regulation exempts the following services from the KSeF obligation:

• air traffic control and surveillance,
• for which route charges are levied,
• documented by invoices issued monthly by the Central Route Charges Office (CRCO) EUROCONTROL on behalf of the Polish Air Navigation Services Agency.

This is a specific sectoral exception, particularly relevant for entities in the aviation industry.

4) KSeF and VAT-exempt financial and insurance services

The exemption covers:

• VAT-exempt financial and insurance services,
• documented by simplified invoices with a narrower scope of data.

For companies, this means that in this segment, National E-Invoicing System (KSeF) will not be a mandatory tool for all invoices – and the form of documentation depends on the type of service and the scope of data required by law.

5) KSeF and self-invoicing – foreign purchaser without a VAT number

KSeF is not mandatory for invoices issued as part of self-invoicing by a purchaser who is a so-called foreign entity if they do not have a VAT number.

6) KSeF and self-invoicing – foreign seller without a NIP

The exemption also applies to invoices issued by the purchaser as part of self-invoicing, when the purchaser has been authorised to self-invoice by a taxpayer who is a so-called foreign entity, if that taxpayer does not have a tax identification number (NIP).

Exception to the exemption – when can an invoice be issued in the E-Invoicing System (KSeF) despite the lack of obligation?

The regulation provides for a special case in which a foreign purchaser without a NIP number may issue an invoice in KSeF. This is the case for intra-Community supply of goods, when such a purchaser is identified in their Member State by an EU VAT number.

This is important because it shows that the regulations allow the system to be used in certain scenarios, even though there is no obligation to do so.

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National E-Invoicing System (KSeF) in Poland and simplified invoices – what changes does the regulation bring?

KSeF and new requirements for simplified invoices from 1 February 2026.

The second regulation (Journal of Laws, item 1742) adapts the rules for issuing simplified invoices to the mandatory KSeF.

In particular, this applies to:

• taxpayers exempt from VAT,
• transactions exempt from VAT documented with simplified invoices.

The most important change is practical and unambiguous:

From 1 February 2026, simplified invoices issued in KSeF must include the issuer’s tax identification number (NIP).

Providing the issuer’s NIP becomes necessary because this number is essential for fulfilling the obligation to issue invoices in KSeF – it is an element of identification in the system.

National E-Invoicing System (KSeF) and simplified invoices outside the system

The regulation also emphasises that when a simplified invoice is issued outside KSeF, the taxpayer is still not required to provide the issuer’s tax identification number (NIP):

• simplified invoices in KSeF – with the issuer’s NIP,
• simplified invoices outside KSeF – without the obligation to provide the issuer’s NIP (in certain cases).

Purchaser’s NIP on a simplified invoice

Additionally:

• The purchaser’s NIP, if used, should be provided on the simplified invoice.

This is important for B2B settlements and identification of the parties to the transaction.

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How to use the National E-Invoicing System (KSeF) in Poland – authorisations, ZAW-FA and authentication

Rules of operation for taxpayers and integrators

The third regulation (of 12 December 2025) on the use of KSeF is the act of greatest organisational significance.

It does not describe exceptions or data on the invoice, but regulates:

• who uses KSeF and how,
• how authorisations are granted,
• what authentication looks like,
• how invoices with attachments are handled,
• how to mark invoices made available outside KSeF.

From an entrepreneur’s perspective, this is a document that directly affects the implementation and security of processes.

National E-Invoicing System (KSeF) – authorisations and procedures (including ZAW-FA)

The regulation specifies:

• the types of authorisations to use KSeF,
• the procedures for granting and revoking authorisations,
• and the ZAW-FA notification template.

For companies, this means that they need to develop an internal policy: who issues invoices in KSeF, who receives them, who has access to the data, and how to handle the delegation of authorisations.

Authentication and identity verification

The regulation governs:

• user authentication methods,
• technical requirements,
• verification of the invoice issuer’s identity (e.g. using a certificate).

In practice, this means that the implementation of the National E-Invoicing System (KSeF) is not only a matter of sending XML, but also a mechanism for user identification and security.

Access to invoices without additional authentication

The following has also been regulated:

• the scope of data required to access invoices in KSeF without additional authentication.

This is important for automation, integration of accounting systems, document circulation and access in service models.

Marking invoices made available outside the system

The regulation specifies the rules for marking invoices sent to KSeF and made available outside the system in order to ensure:

• verification,
• authenticity of origin,
• integrity of content.

This is important for entrepreneurs in the context of their relations with contractors: not every recipient will use the same channels, and at the same time, the document must be reliably verifiable.

Invoices with attachments – procedure and technical requirements

One of the most practical elements of the regulation are the procedures concerning invoices with attachments:

• from notification of the intention to issue them,
• through confirmation of the possibility,
• to technical requirements.

This is particularly important for industries where the invoice is only a ‘cover’ and the settlement details are in the attachment (e.g. service settlements, fees, statements, reports).

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JPK_VAT in Poland’s National E-Invoicing System (KSeF) from 1 February 2026 – KSeF number, OFF/BFK/DI markings and correction rules

JPK_VAT adapted to KSeF – what is changing?

The fourth executive act (of 12 December 2025) adapts the regulation on data contained in VAT returns and records to statutory changes and the practical operation of KSeF.

The essence of the change:

• the KSeF invoice number is to appear in the sales and purchase records in JPK_VAT with the return,
• and at the same time, a method for recognising documents from outside KSeF has been provided for.

If you want to know more about the OFF, BFK and DI markings, the obligation to show the KSeF number on the purchase side and the rules for corrections after assigning a KSeF number, see our previous article: Draft regulation: new invoice markings in JPK_VAT in connection with KSeF.

KSeF in JPK_VAT – new markings (OFF, BFK, DI)

Three markings have been introduced to enable the display of documents other than invoices from KSeF:

• OFF – an invoice referred to in Article 106nf of the Act, without a KSeF number on the date of submission of the records,
• BFK – an electronic or paper invoice,
• DI – a document other than an invoice issued via KSeF.

This is important for companies because, in practice, for a certain period of time (and in exceptional cases also permanently), the following will operate in parallel:

• invoices from KSeF,
• invoices outside KSeF,
• documents other than invoices.

KSeF number in JPK_VAT – regardless of the invoice issuance mode

The KSeF number must be provided for invoices issued in KSeF regardless of the mode:

• standard mode,
• offline24,
• failure,
• system unavailability.

In each case, the KSeF number is shown in JPK as of the date of submission of JPK_VAT with the declaration.

JPK corrections – when is it necessary to make corrections and when is it not?

The regulation contains a very practical explanation, which is important for companies:

In principle, there is no requirement to correct the records just to add the KSeF number.

If the KSeF number had not yet been assigned on the date of submission of the JPK, the regulation does not require automatic correction.

Exception – offline24 after submitting the JPK

The obligation to make corrections arises only when:

• sales invoices were included in the sales records,
• they were issued offline24,
• and the KSeF number was assigned after the JPK_VAT was submitted with the declaration.

In practice, the Ministry of Finance indicates that such cases are to be sporadic, because the deadlines are set in such a way that it is usually possible to obtain the KSeF number earlier.

Automation – less burden on taxpayers

The explanations provided by the Ministry of Finance also indicate that:

• the Ministry of Finance software (e-mikrofirma) will include solutions that automatically feed JPK_VAT with invoices received in KSeF together with the KSeF number,
• and commercial systems can be expected to include similar integrations and links between the accounting system and KSeF.

Deadline for applying changes to JPK_VAT

The regulation applies to JPK_VAT records with declarations submitted for settlement periods from 1 February 2026.

The standardisation of the date is intended to reduce costs and unnecessary changes in companies (in the context of KSeF obligations).

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Poland’s National E-Invoicing System (KSeF) in practice – what should entrepreneurs do after the regulations are signed?

Below is a practical list of areas that, taking into account the regulations described, should be included in every company’s checklist.

1) Map whether you use exemptions (Journal of Laws, item 1740)

Companies should answer the question:

Are there any documents in our costs or revenues that are exempt from the KSeF obligation, e.g.:

• single-use tickets for passenger transport,
• documents for toll motorway journeys,
• invoices/specific financial and insurance documents,
• self-invoicing with foreign entities without a tax identification number?

If so, procedures must be prepared for how these documents will be entered into the accounting system and the JPK (BFK/DI or other appropriate markings).

2) Analyse the rules for simplified invoices (Journal of Laws, item 1742)

When circulating simplified invoices, the following difference must be taken into account:

• in KSeF – the issuer’s VAT number will be mandatory,
• outside KSeF – in some cases, it will still not be necessary to provide it.

Companies must ensure that their invoicing systems distinguish between these scenarios, especially for VAT-exempt sales.

3) Organise authorisations and responsibilities (ZAW-FA)

Access management is an important element:

• who is authorised to issue invoices in KSeF,
• who has the right to receive and view them,
• who manages authorisations,
• what roles the accounting office or external operator has.

This is an area that has a real impact on the risk of errors and fraud.

4) Adjust reporting (KSeF number + OFF/BFK/DI)

Accounting and systems should be prepared for:

• storing and transferring the KSeF number to JPK,
• handling OFF/BFK/DI markings,
• understanding the situation of corrections (offline24).

5) Prepare for technical processes and invoices with attachments

If your company issues invoices with attachments (statements, reports, settlements), it will be necessary to:

• determine when an invoice has an attachment,
• prepare the notification process and requirements,
• adjust integration and formats.

getsix® supports companies in the process of adapting to KSeF. As a Microsoft partner, we implement the Microsoft Dynamics 365 Business Central system, which is fully integrated with KSeF and streamlines financial and accounting processes. We also offer the Customer Invoice and Workflow Portal with a mobile application – a modern tool for the circulation, approval and verification of invoices. We encourage you to contact the getsix® team to select the optimal solution for your company and prepare it for the upcoming changes.

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National E-Invoicing System (KSeF) in Poland 2026 – what do the four regulations offer entrepreneurs?

Four executive regulations to KSeF create a complete implementation map:

• they exclude certain documents from the KSeF obligation where it is technically impossible to issue them as structured invoices,
• they clarify simplified invoices and indicate that the issuer’s tax identification number (NIP) is required in KSeF,
• they organise the rules for using National E-Invoicing System (KSeF): authorisations, ZAW-FA, authentication, access, markings, attachments,
• they link KSeF with JPK_VAT: KSeF number in the register and three markings for documents outside KSeF (OFF/BFK/DI),
• they limit the burden of JPK corrections – corrections are not automatic, with the exception of offline24 after assigning a KSeF number.

For companies, this means one thing: the implementation of KSeF in Poland is an organisational and technical project that concerns not only invoicing, but also VAT records, reporting, system integration and authorisation management.

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Legal basis:

• Regulation of the Minister of Finance and Economy of 7 December 2025 on cases in which there is no obligation to issue structured invoices (Journal of Laws 2025, item 1740).
• Regulation of the Minister of Finance and Economy of 7 December 2025 amending the regulation on issuing invoices (Journal of Laws 2025, item 1742).
• Regulation of the Minister of Finance and Economy of 12 December 2025 on the use of the National e-Invoice System (Journal of Laws 2025, item 1815).
• Regulation of the Minister of Finance and Economy of 12 December 2025 amending the regulation amending the regulation on the detailed scope of data contained in tax returns and records in the field of goods and services tax (Journal of Laws 2025, item 1800).

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If you have any further questions or require additional information, please contact your business relationship person or use the enquiry form on the HLB Poland website.

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