July 2025 update – KSeF 2.0 is here
The Polish Ministry of Finance released the final FA(3) invoice schema and KSeF API 2.0 documentation on 30 June 2025, confirming that the KSeF (Krajowy System e-Faktur) platform is on track for full-scale implementation starting in February 2026.
Following recent legislative developments, Poland’s parliament has passed legislation introducing phased mandatory e-invoicing, based on annual turnover and monthly sales thresholds:
- From February 1, 2026, electronic invoicing will be mandatory for businesses with annual sales exceeding PLN 200M (approximately $54 million).
- From April 1, 2026, the requirement will extend to smaller businesses, mandating them to use the government-run e-invoicing clearing system.
- Entities whose monthly revenue does not exceed PLN 10,000 will be allowed to switch to e-invoicing by December 31, 2026.
The penalty-free grace period for the new e-invoicing system will end on 31 December 2026, after which all eligible companies must comply or face fines. Notably, November 2025 will also see the release of the mobile version for the Taxpayer Application.
This mandate, initially planned for mid-2024, was delayed due to technical issues with the system’s initial design but is now moving forward with a clear deadline and phased implementation.
What is KSeF?
KSeF is Poland’s national e-invoicing platform. It is designed to receive, validate and archive structured electronic invoices in the FA(3) XML format.
KSeF core functions:
- Accept structured XML invoices (FA(3))
- Apply KSeF IDs and timestamps
- Support real-time API and Offline24 submissions
- 10-year document archiving
- Validation and rejection of invoices electronically
- KSeF also supports real-time reporting of invoices, providing businesses with immediate validation and confirmation of submission.
- KSeF’s Offline24 mode offers flexibility for taxpayers who face connectivity issues, allowing them to submit invoices by the next business day if real-time submission is not possible.
Who must comply?
Mandatory KSeF e-invoicing applies to all B2B domestic transactions involving:
- Companies established in Poland
- Non-resident companies with a fixed establishment (FE) in Poland
Issuing invoices through the KSeF portal/API will be mandatory after the deadline. Paper or PDF invoices will no longer be sufficient for compliance, and businesses that fail to adapt will face penalties.
Voluntary:
- B2C invoicing
- Use of KSeF by non-established, non-registered suppliers
Tip: Businesses registered for VAT in Poland but unsure about FE status should assess this early. GVC offers fixed establishment assessments and VAT advisory as part of our onboarding.
Key implementation timeline
Mobile version of the Taxpayer Application released
Applications for an Issuer Certificates from November 1, 2025, for “offline24” invoicing in case of system failure.
What makes this reform different?
Unlike traditional e-invoicing or e-reporting systems, KSeF is a centralised validation and transmission platform that fully replaces SAF-T (JPK_FA) for users who adopt it. It enables real-time government access and reduces manual errors.
GVC‘s specialists have helped companies navigate similar platforms across the EU, including SdI (Italy), RO e-Factura (Romania), and France’s upcoming PPF system.
What sets us apart is that we integrate e-invoicing into your end-to-end VAT lifecycle—not just a technical layer.
KSeF vs. PEF – What about B2G?
Poland’s PEF platform remains valid for B2G transactions using Peppol BIS 3.0. However, suppliers are now encouraged to issue e-invoices directly via KSeF, which will assign a compliant KSeF ID.
KSeF is expected to fully support both B2G and B2B under a unified model by 2026.
What about interoperability?
Poland’s FA(3) schema is not EN 16931-compliant. However, the Ministry has indicated future alignment with Peppol CIUS through extensions. This matters for:
- Multinationals using EN 16931/UBL standards
- Service providers facilitating cross-border compliance
GVC’s e-invoicing solution bridges this gap, translating your invoice data between national and EU-compliant formats, so you don’t lose time or accuracy across jurisdictions.
GVC works with your tax, finance and IT teams to turn this checklist into a working roadmap.
Why choose GVC?
GVC delivers more than e-invoicing; its comprehensive solution combines e-invoicing and indirect tax compliance services. We don’t just handle file transmission or basic integration. We provide comprehensive solutions that integrate e-invoicing into your full VAT lifecycle, ensuring long-term compliance and efficiency.”
- Support for both resident and non-resident companies
- ERP integration and FA(3) schema validation
- API connection with real-time and Offline24 setup
- Data reconciliation with VAT returns, SAF-T, and ViDA
- Expert-led onboarding for finance and IT teams
Unlike software vendors, GVC provides context, compliance and continuity. We speak your language—whether it’s XML, ERP or EU VAT.
KSeF isn’t just another compliance obligation. It’s a chance to optimize your Polish VAT and reporting workflows in a way that supports broader EU obligations under ViDA.
Learn how our solutions can simplify compliance and keep you ahead of regulatory changes.