EU · Ministerstwo Finansów / KAS
Poland
Updated in last 30 days·Atlas data current as of
KSeF 2.0 launches in 2026 after multiple delays. FA(3) replaces FA(2) from 1 Feb 2026. Large taxpayers from 1 Feb 2026; all VAT from 1 Apr 2026; micro-entrepreneurs (monthly sales <= PLN 10k) from 1 Jan 2027. Two transitional reliefs matter in 2026: small businesses may keep issuing paper or other electronic invoices until 30 Sep 2026, and offline mode is permitted until 31 Dec 2026 where KSeF is unreachable. No penalties for KSeF violations through 2027; deferred on 16 Sep 2026 and now due 1 Jan 2028. The obligation to use KSeF is unchanged. Token authentication was made permanent (its 31 Dec 2026 sunset was removed).
Cloudare has shipped 1 🇵🇱 Poland integration · talk to us →// Phased rollout
- 01 Jan 2022 · liveVoluntary KSeFOptional use of KSeF for B2B invoicing.
- 01 Feb 2026 · liveMandatory — large taxpayersLarge VAT taxpayers must issue via KSeF 2.0.2024 gross sales > PLN 200 million
- 01 Apr 2026 · liveMandatory — all VATAll other VAT-registered taxpayers.
- 30 Sept 2026 · liveSmall-business paper relief endsTransitional permission for small businesses to keep issuing paper or non-KSeF electronic invoices expires. After this date they must issue through KSeF like everyone else.Small businesses using the transitional relief
- 31 Dec 2026 · upcomingOffline mode relief endsOffline issuance, permitted through 2026 where KSeF connectivity is unavailable, ends. From 2027 an invoice not delivered to KSeF is not a valid invoice.
- 01 Jan 2027 · upcomingMandatory — microSmallest taxpayers join KSeF.Monthly turnover < PLN 10,000
- 01 Jan 2028 · upcomingPenalties beginFinancial penalties for issuing outside KSeF take effect. Deferred from 1 Jan 2027 by the Ministry of Finance on 16 Sep 2026; the obligation to use KSeF itself is unchanged throughout.
// Penalties
Up to 100% of VAT shown on the invoice, or 18.7% of total invoice amount where no VAT is shown; suspended until 1 January 2028.
// What you have to do
- Confirm which of your flows are in scopeB2B is phased, B2G is mandatory, B2C is voluntary.
- Emit FA(3) XSD (XML)Your ERP must produce this syntax, not a PDF or a print stream.
- Connect via KSeF 2.0 API (api.ksef.mf.gov.pl/v2)This is the channel, separate from the format. Most projects underestimate it.
- Plan for the Clearance modelThe regulator validates before the invoice is legally issued, so a rejection blocks the sale. Build the rejection path first.
- Retain for 10 yearsArchive the structured original, not a rendering of it.
- Understand the exposureUp to 100% of VAT shown on the invoice, or 18.7% of total invoice amount where no VAT is shown; suspended until 1 January 2028.
// ERP implementation notes
SAP S/4HANA (incl. DRC) & SAP ECC
SAP DRC Poland: PL_INVOICE eDocument scenario for KSeF 2.0; FA(3) generation; mTLS authentication via SAP CPI.
Microsoft Dynamics 365 (F&O + Business Central)
D365 F&O Poland ER for FA(3); Electronic invoicing service connects to KSeF 2.0 API.
Odoo (Community + Enterprise)
l10n_pl_edi_ksef supports FA(3) and KSeF 2.0 token-based auth.
// Implementation playbook
Cloudare has shipped 1 Poland integrations. We will email you the full implementation playbook for Poland — typical project plan, ERP-by-ERP gotchas, regulator-specific edge cases, sample test data. No marketing.
// Frequently asked questions
What's the KSeF status — is it live yet?
KSeF (Krajowy System e-Faktur) has been live as a voluntary system since 2022. Mandatory rollout was originally scheduled for July 2024, then deferred multiple times. Current target: 1 February 2026 for businesses with turnover > PLN 200M, and 1 April 2026 for all other taxpayers. Verify the latest deferral status with the Ministry of Finance.
FA(3) versus older versions — what changed?
FA(3) is the current KSeF schema (the third major iteration). Compared to FA(2) it adjusts field requirements, adds support for specific transaction types (factoring, split payment marking), and tightens validation. If your integration is on FA(2), plan an upgrade — the Ministry has confirmed FA(3) for the mandatory go-live.
What's distinctive about KSeF as a clearance model?
It's a true clearance: every invoice is sent to KSeF, validated, assigned a KSeF number, and the customer fetches it from KSeF (not from the supplier directly). This makes KSeF the system of record. Off-network 'email a PDF' workflows become non-existent for in-scope transactions.
Which ERPs have native KSeF connectors?
SAP DRC Poland is the most mature; Oracle Fusion via Tax Reporting Cloud + Polish localisation; Microsoft Dynamics 365 F&O with Polish localisation; Comarch ERP (large Polish market share) has native KSeF; Sage Symfonia (popular in Polish SME). Odoo and Zoho have functioning modules. SAP ECC needs third-party middleware.
Do we need a Polish entity to register on KSeF?
You need a Polish NIP (tax identification number). Foreign entities VAT-registered in Poland can use their Polish VAT number; entities without a Polish presence cannot directly invoice through KSeF and must rely on the buyer's mechanism.
What's the consequence of an invoice not being on KSeF post-mandate?
It's not a valid VAT invoice. Buyers cannot claim input VAT on invoices that didn't go through KSeF. This creates strong incentive throughout the supply chain — your buyers will reject non-compliant invoices because their VAT recovery depends on it.