As an increasing number of countries embrace e-invoicing mandates, Poland’s actions are part of a broader, global trend preparing the National Electronic Invoicing System, known as
KSeF, for mandatory use. Since its active development by the Polish Ministry of Finance in October 2021, companies now have the opportunity to willingly transition to e-invoicing before the mandate goes into effect.
KSeF in Poland – Definition
The National e-Invoice System, or KSeF (Krajowy System e-Faktur), is a platform designed by the Ministry of Finance to promote the use of electronic invoices to centralize the invoice exchange, eliminate the VAT gap, and combat tax fraud. By utilizing KSeF, taxpayers can issue, receive, and store e-invoices.
The Timeline of Mandatory e-Invoicing in Poland
KSeF was scheduled to launch on July 1, 2024; however, the Polish Ministry of Finance postponed the implementation due to critical system errors. The new date has not yet been announced.

At the beggining of April Ministry of Finance published a draft bill featuring points brought up during most recent round of public consultations. The Ministry awaits further comments on the draft document until April 19th. Specifics regarding the updated schedule will likely be disclosed no earlier than the end of April. The legislative procedure is projected to conclude by the end of June 2024.
The initial date followed the European Commission’s endorsement of Poland’s request to amend particular regulations concerning value-added tax. On March 30, 2022, the European Commission put forth a proposal to the EU Council, authorizing Poland to introduce an electronic invoicing system – KSeF.
Following implementation, nearly all B2B and B2G invoices must be issued or received through KSeF, eliminating traditional paper invoices from these business models. For now, B2C transactions are excluded from the electronic invoicing mandate.
Structured Invoices in KSeF
The Polish National System of e-Invoices mandates the use of structured invoices stamped with a KSeF ID number. Invoices must adhere to the logical structure of the FA(2) e-invoice in XML format and contain all legally required data. Additionally, all structured invoices must be archived for 10 years. Small businesses handling limited amounts of invoices can use the government-provided system, while larger companies should opt for commercial systems integrated with Poland’s National e-Invoice System like Comarch EDI.
7 KSeF Benefits for Taxpayers
1.
Enhanced Financial Liquidity: Accelerated VAT returns from 60 to 40 days to improve cash flow for companies.
2.
Reduced Compliance Burden: Simplified tax obligations streamline processes, making it easier for taxpayers to meet compliance requirements.
3.
Minimized Financial Errors: Automation and lowered risk of human error in financial transactions ensures more accurate financial reporting.
4.
Efficient Transaction Handling: Faster documentation of transactions through automation speeds up the invoicing process.
5.
Cost Savings and Resource Optimization: Exemption from preparing JPK_FA file for e-invoices transactions results in cost savings and optimizes resources.
6.
Secure Data Management: Ensured security in the storage and access to e-invoices protects sensitive financial data, providing peace of mind for taxpayers.
7.
Economic Efficiency: Alignment with the EU trends and the move towards e-invoicing contributes to the economic efficiency.
Implementing electronic invoicing in Poland is intended to streamline processes not only for taxpayers but also for tax authorities. Primarily, the new mandate aims to reduce the VAT gap and aims to bolster VAT revenues for the state budget Between 2015 and 2019, the gap decreased by approximately 80%.
KSeF serves as an effective instrument for enhancing the VAT system through the application of cutting-edge technologies. Moreover, KSeF facilitates continuous transaction monitoring, diminishing the necessity for tax authorities to conduct extensive inspection on entrepreneurs.
Implementation and Preparation for KSeF
In times of inevitable change, understanding what to anticipate is crucial, particularly in the context of legal modifications. Avoid waiting until the last minute to implement e-invoicing in your company; instead, begin harnessing the aforementioned benefits, adapt to the new processes, and do so at your own pace.
KSeF, Poland's upcoming e-invoicing system, streamlines invoice processing for businesses. It enhances tax compliance, cuts costs, and ensures secure data management, making it a win-win for businesses and the government.
To prepare for KSeF, businesses should familiarize themselves with the mandate details, assess current IT solutions, and ensure compliance. Educate employees, especially those involved in AP/AR processes, and address any issues in invoicing processes. Begin leveraging the benefits of e-invoicing well in advance of the mandatory deadline.
KSeF in Practice: Registration, Issuance and Reception of Invoices
KSeF is accessible to both individuals and non-individual entities, with primary ownership authorization automatically conferred upon the taxpayer. However, accountants and other staff members must submit a notice to the tax administration to obtain permission to utilize the National e-Invoice System.
It's worth noting that the KSeF software doesn't allow invoice attachments. To send them, taxpayers must do so separately, outside the system. Commercial solutions, such as Comarch EDI, enable the transmission of supplementary files alongside the generated e-invoices for delivery to the customer.
Once a seller issues a structured invoice through KSeF, it becomes immediately available in the system for the recipient.
The National e-Invoice System in Poland does not notify the taxpayer every time a new invoice is available. Instead, the taxpayer has to log into the portal and 'ask' KSeF about available invoices. To access the invoice, the buyer's recipient can download the file directly from KSeF. Larger enterprises can use dedicated solutions provided by specialized suppliers, such as Comarch, which use the available API interface.
Flexible Invoicing Options for Foreign Entities
Entities operating outside Poland are not obligated to use KSeF. Invoices to such entities can be sent through mutually agreed-upon methods, often using formats like PDF.
Integration with KSeF: In-House or Outsourced?
Companies can choose between in-house integration, requiring significant resources, or utilizing commercial EDI solutions. Numerous Polish businesses choose commercial solutions that facilitate smooth implementation, compliance with global invoicing laws, and provide other useful functionalities.
KSeF Integration with Comarch
As an IT provider with nearly 30 years of experience, Comarch has been actively engaged with KSeF since the very beginning. Comarch now supports businesses looking to embrace the new era of invoicing through the Comarch EDI platform. This advanced, cloud-based solution operates on a Software as a Service (SaaS) model, facilitating seamless data exchange. Any changes in e-invoicing mandates worldwide are promptly addressed within the software, including those specific to KSeF.
Discover more information about the National e-Invoice System in Poland and Comarch EDI – download Comarch’s
white paper that will guide you through this transition.