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Poland is preparing further changes related to the National e-Invoicing System (KSeF). The Ministry of Finance and Economy has proposed postponing the application of financial penalties for certain violations related to the use of the system until 1 January 2028.

The relevant draft legislation was published on 22 September 2026. It is important to note that, at this stage, this is still a proposed amendment and not a rule that has already entered into force.

What changes are being proposed?

Under the current rules, provisions introducing financial penalties for certain KSeF-related violations are due to take effect on 1 January 2027.

The new proposal would postpone this deadline by one more year, until 1 January 2028.

This would give businesses an additional transition period to adapt their accounting software, internal procedures and e-invoicing processes.

Does this mean businesses will not have to use KSeF in 2027?

No. The proposed postponement concerns penalties, not the obligation to use KSeF itself.

If a business is required to use KSeF, the temporary absence of financial penalties does not remove that obligation.

Under the proposal, if the tax authorities determine that a business is not using KSeF despite being required to do so, the Polish National Revenue Administration (Krajowa Administracja Skarbowa, KAS) may first remind the business of its obligation to comply with the rules.

If there is no response, the tax authorities may then verify whether the incorrect use of KSeF is leading to irregularities in VAT settlements.

Who is already subject to mandatory KSeF?

The implementation of KSeF in Poland is taking place in stages.

From 1 February 2026, the obligation to issue invoices through KSeF began to apply to the largest taxpayers whose sales revenue for 2024 exceeded PLN 200 million.

From 1 April 2026, the system became mandatory for other businesses, except in cases covered by transitional exemptions provided for by law.

For the smallest taxpayers, whose total gross sales documented by such invoices do not exceed PLN 10,000 per month, the transitional period remains in force until the end of 2026.

What will change from 1 January 2027?

Under the current rules, from the beginning of 2027 KSeF is also expected to become mandatory for businesses that, until the end of 2026, benefit from an exemption due to the low volume of invoices they issue.

From 1 January 2027, the transitional option of issuing certain invoices through cash registers instead of KSeF is also expected to end.

Businesses that are still using transitional exemptions should therefore check in advance whether their accounting systems and software are ready to operate under the new framework.

What should businesses check now?

Even if the proposal to postpone the penalties is adopted, businesses should not delay their preparations for KSeF until 2028.

It is important to verify who in the company has access to the system, whether user permissions have been configured correctly, whether the accounting software is integrated with KSeF, and whether employees understand the procedures for issuing and receiving electronic invoices.

Particular attention should also be paid to cooperation with the accounting department or accounting provider. Businesses should clearly understand who is responsible for issuing invoices, submitting them through KSeF and monitoring potential errors.

The changes have not yet entered into force

At the time of publication, the proposal provides for financial penalties for KSeF-related violations to begin applying from 1 January 2028.

However, the legislative process is still ongoing. Businesses should therefore continue to follow the rules currently in force and monitor the further progress of the proposed amendments.

Advisor Poland helps businesses in Poland organise their accounting, tax reporting and internal processes in preparation for new regulatory requirements.