Poland – Status of the B2B E-Invoicing Project

In August 2023, the President of the Republic of Poland signed the Act amending tax on goods and services, including implementing the mandatory use of e-invoices. Following the plan, all businesses established in Poland, including SMEs, must adopt the KSeF system. 

The planned timeline was that, as of July 2024, all VAT-registered businesses would use the KSeF system to issue and receive e-invoices. In contrast, VAT-exempt businesses would have the same obligation from January 2025.

The Course of Introduction to Regulation

On November 27, 2023, the Poland Ministry of Finance (MoF) announced the beginning of consultations on two implementing acts regarding the universal application of the KSeF from July 1, 2024. On the same occasion, MoF published a draft regulation on using the National e-Invoice System and a draft regulation amending the regulation on issuing invoices. The First consultation was scheduled for December 18, 2023.

The implementation of the KSeF was postponed at the beginning of 2024 due to many critical errors detected in the system. This was followed by several consultations held from February 16 to March 1, 2024, which resulted in additional changes to the system, which were announced on April 3, 2024, and new consultations in April on the draft legal solutions for the mandatory KSeF.

After finishing public consultations and completing an external audit of the KSeF, MoF announced that the system's implementation would be completed in two phases.

Current Regulatory Framework

On June 5, 2024, the President of the Republic of Poland signed amendments to the VAT Act, thus officially extending the deadline for implementation of the mandatory KSeF and confirming that it will be completed in two phases:

1. February 1, 2026 - Businesses with a turnover exceeding PLN 200 million (app EUR 46 million) in 2025,

2. April 1, 2026 - All other businesses.

In addition, MoF made available the production version of the KSeF Mobile Application, which allows the issuance of basic invoices in KSeF and their corrections on a smartphone, as well as the view of received and issued invoices. 

After this announcement, another KSeF consultation meeting was held by the MoF and the National Revenue Administration (KAS) to present all the results of previous consultations, publish a timeline, and discuss with participants steps for further simplification and introduction of new functionalities of the system, such as:

• enabling the sending of invoice attachments for industries issuing invoices with a complex scope of data,

• modification of the logical structure of e-invoices, including in terms of the rules for indicating the payment deadline,

• equalization of KSeF environments - full implementation of "business" functionalities - issuing invoices in KSeF in the target model, but without changing taxpayers' obligations.
  

Conclusion

Throughout this process, from the announcement of the plan to implement the KSeF system to the final timeline, Poland showed a strong dedication to persevering in its plans and including the public and actors who will feel these changes the most.

The current timeline allows all businesses to adopt these changes and provides additional time to prepare to meet mandatory e-invoicing requirements.