oland KSeF E-Invoicing System: New Implementation Steps & Timeline for 2026

Poland has been struggling to implement an e-invoicing system, also known as KSeF, for some time now. After postponing the implementation to remove errors detected in the system, conducting several consultations that resulted in changes, and setting a new implementation timeline, the Ministry of Finance (MoF) presented a draft of the law that should make the implementation process more efficient.

The MoF is confident that the draft law will be adopted in the next Council of Ministers meeting and will soon officially become law.

The Proposed Implementation Law

The draft law affirms the previously set timeline in June this year, meaning that introducing mandatory use of KSeF for all taxpayers, including those VAT-exempt, will be completed in two phases. The first phase begins on February 1, 2026, when all companies with sales above PLN 200 million will have to issue and receive e-invoices through the KSeF system.

The second phase begins on April 1, 2026, when all other businesses will become subject to mandatory e-invoicing rules.

However, the draft law also postpones several requirements until July 31, 2026, such as the obligation to include the KSeF number in e-invoice payment and penalties for noncompliance with KSeF rules and regulations. Additionally, taxpayers with low invoice volume and value can issue invoices in the current format until September 20, 2026. These taxpayers are referred to as digitally excluded taxpayers.

As the final step to help taxpayers adopt and adapt to KSeF requirements, the offline mode will be available for all taxpayers until the end of 2026. MoF stated that the full technical functionality of the KSeF must be secured before the mandatory e-invoicing rules come into effect.

Conclusion

The next step in this pre-implementation process is for the Council of Ministers to approve this draft law. However, with all the effort invested in this process, it is clear that the Polish government aims to implement mandatory B2B e-invoicing rules in 2026. This leaves all businesses subject to these rules more than enough to prepare for inevitable upcoming changes and ensure compliance with the KSeF requirements.

Source: EY, VATabout - Poland – Status of the B2B E-Invoicing Project