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This article answers the following questions:
- When will KSeF be obligatory?
- What actions related to KSeF are being taken by the Ministry of Finance?
- Will the introduction of KSeF be postponed and are further public consultations on structured electronic invoices possible?
The obligatory National e-Invoicing System to be introduced soon – the Ministry of Finance has confirmed the schedule for KSeF
In response to the interpellation no. 8479, the Polish Ministry of Finance has confirmed that the obligation to use the National e-Invoicing System (Polish: Krajowy System e-Faktur, KSeF) will be introduced according to the current schedule. The obligation to use KSeF and issue e-invoices will be imposed:
- from 1 February 2026 – on taxpayers whose annual revenue from the sales of goods and services exceeds PLN 200 million,
- from 1 April 2026 – on the remaining taxpayers operating in Poland.
The Department has also pointed out that no further postponement of the dates is expected.
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The requirement to use KSeF is currently a priority of the Ministry of Finance
The Ministry of Finance emphasises that the obligation to issue structured invoices via KSeF remains one of its top priorities. At the same time, the Department is carrying out intensive works on the new system architecture and verifying business and legislative premises. The aim of these activities is to ensure the effectiveness, proper performance, and reliability of the final version of the system.
The new draft act concerning issuing invoices via KSeF is scheduled for examination by the Council of Ministers in the second quarter of 2025 and will contain the main points put forward by entrepreneurs in the consultations to-date.
Importantly, the Ministry of Finance does not preclude the possibility to run another series of consultations. However, this situation raises some doubts as to whether taxpayers will have enough time to prepare for the new obligations.
Vacatio legis still uncertain
Despite the fact that the Department has declared to continue the dialogue with entrepreneurs (and has announced to take information measures), it has not yet precisely specified how much time to prepare for the new obligations related to issuing structured invoices through KSeF will be given to taxpayers.
The lack of clear information raises legitimate concerns in companies – both large and SMEs – which must plan costly and time-consuming activities, such as adjustment of their accounting systems, employee training, or integration testing. Further public consultations, if held, may additionally delay the entire legislation process, thus giving entrepreneurs less time to effectively implement the system when its final version is known.
What happens next with electronic invoices in Poland?
Summing up, the key takeaway from the response of the Ministry of Finance is that the date of the obligatory introduction of KSeF for most entities is April 2026. However, entrepreneurs must still wait for some time before the final version of KSeF is known.
If you have any questions (or need assistance in preparations), check out our Q&A section regarding KSeF prepared by our tax advisors and feel free to contact RSM Poland experts.
