The Hague, 7 September 2026. On 6 August 2026 the Polish Ministry of Finance published an expanded set of updated KSeF 2.0 manuals and, in doing so, removed the previously announced end date of 31 December 2026 for token authentication. Tokens therefore remain a permanent authentication method rather than a temporary transitional solution. For every organisation, wherever it is based, that supplies Polish customers, runs a Polish establishment or otherwise has to prepare for e-invoicing in Poland, that turns a design choice many integrations had written off as short-lived into a lasting one.
What the ministry published
The ministry released four updated manuals. They cover, in turn, starting to use KSeF, issuing and receiving invoices, additional functionality, and the permission models for VAT groups, local government units and other composite organisational structures. Separate documentation was published for the KSeF web application and for the mobile app.
The ministry also states what businesses should be testing: certificate-based and token-based authentication, delegation of permissions, self-billing, access through Peppol providers, online and offline invoices, QR codes and correction processes. In practice that is a test plan, not a reading list.
KSeF is a clearance model, not a four-corner network
The Krajowy System e-Faktur is Poland’s national e-invoicing system and operates as a clearance model. Invoices pass through a central government platform and are registered there before they are legally valid. That is a fundamentally different approach from the four-corner model Peppol uses, in which two accesspoints exchange documents directly between sender and receiver without government involvement.
The distinction has immediate consequences. Peppol cannot be used for the mandatory B2B submission to KSeF. For B2G invoicing, however, businesses may choose from 1 February 2026 between PEF, the Polish platform that runs on Peppol, and KSeF. An organisation that supplies both Polish public bodies and Polish companies therefore deals with two routes at once.
Who is in scope and from when
The mandate is phased. From 1 February 2026 it applies to taxable persons with more than PLN 200 million in annual turnover, roughly 46 million euro. From 1 April 2026 all other taxable persons follow, and from 1 January 2027 the smallest taxable persons. From 1 February 2026 the mandatory format is FA(3), a structured XML schema that is the Polish implementation of EN 16931.
Scope deserves precision. The obligation attaches to Polish VAT liability and to a fixed establishment in Poland, not to nationality or to the country where a company is incorporated. Foreign companies that are not VAT-liable in Poland do not fall under the B2B mandate, whether they operate from the Netherlands, Germany, France, Spain or elsewhere. Companies that do hold a Polish VAT registration or establishment are in scope, wherever their head office sits. The same logic governs the Belgian e-invoicing mandate, where fixed establishment is likewise the deciding factor.
The legal basis includes the amendment of 16 June 2023 to the Polish VAT Act and Council Implementing Decision (EU) 2022/1003, by which the Council authorised Poland to derogate from the VAT Directive.
Prepare for e-invoicing in Poland: what to do now
For the business with a Polish establishment or VAT registration
- Establish first whether you are in scope. Test against Polish VAT liability and fixed establishment, not against where your company is incorporated.
- Determine your phase: 1 February 2026, 1 April 2026 or 1 January 2027. Where the turnover threshold is unclear, plan for the earliest date.
- Arrange authentication and record who holds which permission. Now that tokens are permanent, you can settle on a lasting set-up instead of a temporary one.
- Set up offline mode with an offline certificate. That mode is optional, but without a working fallback your invoicing stops the moment KSeF is unreachable.
- Assign ownership of the correction process. Corrective invoices in Poland follow their own procedure rather than the credit note you are used to.
- Separate your B2G flow from your B2B flow and make a deliberate choice between PEF and KSeF for public sector invoices.
For the integrator or Peppol Serviceprovider
- Build the FA(3) mapping from your existing EN 16931 model and record, field by field, which Polish elements have no Peppol equivalent.
- Handle the authentication choice inside the connection: certificate and token side by side, with an explicit choice per customer and per environment.
- Implement offline mode including the later submission and the QR codes on offline invoices.
- Test delegation of permissions and self-billing separately. Both touch the permission model and rarely fail on the happy path.
- Document for your customers that Polish B2B traffic does not run over Peppol, so expectations about your service match reality.
For the business trading with Poland without its own Polish VAT liability or establishment
In practice, most businesses fall into neither of the two categories above: they supply Polish customers or buy from Polish suppliers without being VAT-liable in Poland themselves or holding an establishment there. The KSeF mandate does not apply to them directly, but its effects still reach them.
- As a buyer from a Polish supplier: if that supplier is itself in scope, they must still register the invoice in KSeF. You then receive it outside KSeF, typically as a visualisation carrying a QR code, the KSeF identification number and the issue date, for example by email. Ask your Polish suppliers whether they already have this delivery arranged.
- As a supplier to a Polish customer: check whether your customer is itself in scope for KSeF before you invoice, and agree with them how the invoice will be delivered if so.
- Check that your accounting or procurement system can correctly process and archive a QR code and a KSeF identification number, even if you never invoice through KSeF yourself.
- Track your activity in Poland. If your turnover or presence there grows, that can eventually trigger a Polish VAT registration or fixed establishment, moving you into the first category above.
Europe is not converging on one system, it is accumulating them
Poland is not an outlier that will quietly pass. The Netherlands is moving the other way with its B2B mandate built on Peppol towards 2030, Belgium, France and other member states have each chosen their own route, and ViDA makes structured e-invoicing mandatory for cross-border EU transactions from 1 July 2030. For a business with customers or establishments across several EU countries, that means no single standard, but a different system, a different format and a different deadline to support in each one.
The practical question for a business is not which network is technically superior, but which supplier stops it from having to answer that question separately for every country. The provider overview on Peppol.nu can be filtered by service area, which shows which serviceproviders handle both Peppol and country-specific systems such as KSeF. Anyone who would rather prepare for e-invoicing in Poland, or in any other country, through a single party that absorbs the differences between them starts there.
Sources
- Krajowy System e-Faktur (KSeF), Ministry of Finance of Poland
- Podręcznik KSeF 2.0, Part I: Starting to use KSeF (PDF)
- Podręcznik KSeF 2.0, Part II: Issuing and receiving invoices in KSeF (PDF)
- Podręcznik KSeF 2.0, Part III: Additional KSeF functionality (PDF)
- European Commission, eInvoicing in Poland
- Council Implementing Decision (EU) 2022/1003 of 17 June 2022
- Council Directive (EU) 2025/516 (VAT in the Digital Age)
