jurisdiction

Poland

1. Rollout of mandatory national e-invoicing system (KSeF)

Development

1 February 2026: mandatory e-invoicing for large taxpayers (turnover > PLN 200 million or approx. EUR 47,4 million). As of now, large taxpayers must already issue all B2B invoices via the KSeF platform.

1 April 2026: mandatory rollout for all other VAT-registered entities in Poland.

Reception requirement: since 1 February 2026, all VAT taxpayers (regardless of size) were required to be technically capable of receiving and processing structured invoices from the KSeF.

Description

The KSeF has officially moved from a voluntary to mandatory phase. It is a centralised government platform through which all B2B invoices must be issued, received and archived in a specific XML format. Under this regime, an invoice is no longer a PDF or paper document; legally, it only exists once it is uploaded to and validated by the Ministry of Finance’s platform, which assigns it a unique KSeF ID.

This change fundamentally shifts tax compliance from periodic reporting to real-time transaction monitoring by the authorities.

Impact and risk

The primary risk is technical and operational non-compliance, particularly for international groups. Many global enterprise resource planning (ERP) systems (e.g. SAP) were not originally designed to handle Poland’s specific XML schemas and real-time application programming interface (API) communication requirements. If a group’s global software is not properly localised or integrated with specialised “middleware” by the upcoming April deadline, the company will be legally unable to issue valid invoices. This will result in severe commercial risks, including delayed payments from customers and the loss of VAT deduction rights for counterparties.

In addition, the mandatory reception requirement for all taxpayers since February means that even smaller entities must have automated workflows to download invoices from the platform to avoid “invisible” costs and missed payment deadlines.

Future actions

  • Urgent IT integration: groups not yet live must finalise the connection between their global ERP and the KSeF API. Given the complexity, “middleware” solutions are often the fastest path to compliance
  • Fixed establishment (FE) review: international entities should reassess if their activities in Poland constitute a “fixed establishment” for VAT, as this status triggers the mandatory KSeF obligation
  • Process mapping: update internal accounts payable (AP) and accounts receivable (AR) procedures to handle the digital-only document flow