Poland Releases New Draft Regulation on the Use of KSeF

On 1 September 2025, Poland’s Ministry of Finance released an updated draft act on the National e-Invoicing System (KSeF). This version does not change the core framework introduced earlier, but it provides clearer definitions, more detailed explanations, and technical refinements.

Main Clarifications

• KSeF Certificates: Certificates may be issued for up to two years, with the option of renewal. They are used both for authentication in the system and for confirming invoice authenticity and integrity through QR codes. Taxpayers who authenticate with a token until 31 December 2025 will need to use another method, such as a qualified electronic seal, to generate a certificate.
• QR Codes: Structured invoices issued within KSeF and those prepared offline must carry QR codes. In offline mode, two codes are required: an access QR code and a certificate QR code. If an invoice is shared before submission to KSeF, both codes must be included; if shared afterward, only the access QR code is needed.
• Attachments: A clearer definition restricts attachments to data derived from Article 106e(1) of the VAT Act, particularly when invoices involve complex details such as units of measurement, quantities, or net prices. Otherwise, the right to issue invoices with attachments may be revoked. The notification process for issuing invoices with attachments has also been refined. Attachments will form an integral part of the structured XML invoice. KSeF will not accept unstructured files such as PDF or JPG as attachments.
   

The draft act is still at the consultation stage within the Ministry of Finance and has not yet entered into force. An updated FAQ on KSeF has also been published to support businesses in preparing for the upcoming requirements.

There’s more you should know about e-invoicing in Poland – learn more about the new and upcoming regulations.