KSeF 2.0: Poland Moves Closer to Mandatory E-Invoicing

On June 16, 2025, the Polish Ministry of Finance released an updated set of draft laws for KSeF 2.0 - an enhanced version of the National e-Invoicing System (KSeF). The next day, the Council of Ministers held a session to further deliberate the proposals, signaling that the reform is fast approaching legislative finalization.

What’s New in KSeF 2.0?

1. Clarified ‘Offline24’ Mode

Offline invoicing, an essential fallback when internet access is disrupted, now comes with firm boundaries. Any invoice issued to a domestic business with a NIP (tax ID) must still route through KSeF. Its official receipt date will correspond to when it is logged into the KSeF system, reinforcing the platform as the single source of truth for invoice validity.

2. Structured Attachments Policy

A long-requested feature, structured attachments, has been more clearly defined. The new regulations outline how permissions to send such enhanced invoices will be granted, how long they remain valid, and under what conditions they may be revoked.

What Comes Next?

All signs point toward the legislative package being finalized by July 2025, ahead of the phased rollout of mandatory e-invoicing obligations. The implementation will begin on February 1, 2026, for entities whose sales in the previous tax year exceeded PLN 200 million, followed by April 1, 2026, for all other entrepreneurs. A final stage, starting January 1, 2027, will apply to “digitally excluded” taxpayers issuing invoices up to PLN 450 each and not exceeding PLN 10,000 in total monthly sales.

As Poland moves closer to its KSeF milestone, companies should act now: review their invoicing processes, ensure ERP systems are compatible with structured XML, and consider partnering with experienced providers like Comarch to guarantee compliance and minimize disruption.

There’s more you should know about e-invoicing in Poland – learn more about the new and upcoming regulations.