Poland – New Mandatory E-Invoicing System

Poland is introducing mandatory electronic invoicing through the KSeF (Krajowy System e‑Faktur), the national e‑invoicing platform.

The system standardizes the issuance and processing of invoices across all Polish businesses using a unified XML format, with implementation staged between the 1^st of February 2026 and 1^st of April 2026.

The KSeF framework requires businesses to obtain appropriate access authorization, either through qualified electronic seals or the ZAW‑FA authorization form for designated individuals.

The reform aims to streamline invoicing workflows, reduce errors, and strengthen tax compliance oversight.

Who Must Comply?

From the 1^st of February 2026: Mandatory for large enterprises with gross turnover exceeding PLN 200 million in Financial Year 2024.
From the 1^st of April 2026: Mandatory for all other businesses with exception of micro-enterprises.

Micro enterprises with monthly gross sales below PLN 10,000 may defer adoption until the 31^st of December 2026.

Access and Implementation Requirements

To begin issuing e invoices through KSeF, businesses must complete one of the following authorization routes:

1. Obtain a Qualified Electronic Seal – Enables automated, corporate-level access.
2. Submit the ZAW FA Form – Grants access to designated individuals on behalf of the business.

Upon activation, companies will receive a KSeF access statement confirming registration.

All businesses must ensure system access is obtained and implemented before their respective deadlines.

Risks of Non-Compliance

Issuing invoices outside KSeF (when mandatory) or failing to meet system requirements may lead to penalties imposed by the tax authorities, including:

• Up to 100% of the VAT amount shown on the invoice
• Up to 18.7% of the total amount due on invoices where VAT is not indicated

While penalty provisions come into effect on 1^st of January 2027, non compliance may create immediate operational disruptions, particularly where business partners require KSeF compliant invoicing.

How Mercator^® by Citco (Mercator) Can Help

Mercator supports clients with KSeF onboarding, including:

• Obtaining a qualified electronic seal
• Preparing and submitting the ZAW FA authorization
• Guiding clients through each step of the implementation process

For assistance, please contact mercator@citco.com