The Ministry of Finance’s consultation on the national e-invoicing system has taken place in recent days. This is the first consultation of the Ministry of Finance in this area after the amendment to the VAT Act, which postponed the obligation to issue e-invoices. Below, we share with you the key findings from the consultations organised by the Ministry of Finance:
- The effective date of the mandatory KSeF will not change:
- for taxpayers with a turnover of more than PLN 200 million, the KSeF will be mandatory from 1 February 2026,
- while other taxpayers will have to use the KSeF as early as 1 April 2026.
- FA(2) schema change:
- the FA(2) schema currently made available in the test environment will change,
- the changes are intended to accommodate taxpayers’ proposals in the logical structure,
- as announced by the Ministry, the new FA(3) schema is expected to be available from September 2024,
- the implementation of the changes will probably involve additional work for taxpayers.
- Attachments to structured invoices:
- taxpayers will get the possibility to add attachments to structured invoices,
- this possibility can be seen as clearly beneficial from a business perspective.
- Issuing invoices outside the KSeF system
- from 1 February 2026, it will be possible to issue e-invoices without access to KSeF,
- the taxpayer will have to add the e-invoice to KSeF on the next business day at most.
- The paper invoice
- will be reserved for the smallest taxpayers and only for a transitional period,
- the ministry envisages a limit of PLN 450 per invoice, for a maximum total of PLN 10,000 per month.
In addition, the consultation discussed:
- the abandonment of the obligation to ‘self-identify’ the purchaser for income tax purposes,
- invoicing in KSeF for B2C transactions,
- new functionalities and improvements to the system,
- the alignment of the test environment so that it is compatible with the pre-production and production environment,
- the potential postponement of penalties for non-application of the KSeF, and
- new statutory regulations.
The above issues will be discussed during the next consultation of the Ministry of Finance, which will take place in September. New answers to frequently asked questions on structured invoices are planned to be published on the Ministry of Finance website, under the KSeF tab.
