It is time for the final consultations on the National e-Invoice System (KSeF) which will become obligatory for all the entrepreneurs in 2026. Therefore, it is worth recalling how the consultations organized by The Ministry of Finance have proceeded so far and what changes were discussed at each stage of the meetings.
KSeF since when? When will the mandatory KSeF enter into force?
As we know, The Ministry of Finance has decided to postpone the deadline of the obligatory implementation of KSeF, due to major errors that had been found in the system’s operation. As a result, an external IT audit was conducted, based on which the obligation to use e-invoices was delayed. In addition, The Ministry of Finance decided to divide the legislative work into two parts:
The 1st part included the postponement of the obligation to implement KSeF to February 1, 2026, and the retention of a six-month deferral (until the end of July 2026) of the obligations relating to penalties for KSeF errors, the requirement for payments to include the KSeF number (without MPP), and invoices issued from the cash register. The law has already been signed by President Andrzej Duda and published in the Polish Journal of Laws.
The 2nd part included presenting proposals for simplifying obligations regarding the implementation of KSeF, as well as suggesting a two-stage implementation process, according to which the mandatory KSeF is supposed to come into effect:
– On February 1, 2026 – for entrepreneurs whose sales value (including tax) will have had exceeded 200 million PLN in 2025,
– On April 1, 2026 – for the other entrepreneurs.
The two-stage design of the obligatory KSeF implementation process is meant to give businesses more time for consultations and familiarizing themselves with the proposed changes.
Check out one of our Case Studies and see how we carried out the implementation of KSeF in the SAP system for our client. Get to know what challenges we faced, what solutions we applied, and what benefits the company has gained from automating the e-invoicing process in accordance with KSeF regulations.
What were the issues that have been raised at the KSeF meetings to date?
Alongside the audit and analytical activities, The Ministry also arranged consultative meetings with entrepreneurs from various business fields, in order to discuss legal solutions and the functionality KSeF system. So far in 2024 the consultations were organized in the following stages:
February 16 – March 1, 2024: A series of meetings regarding legal solutions and the functionality of the KSeF system.
March 21, 2024: A summary of the consultations held so far and the presentation of proposed changes. Among the proposals were:
– The same mandatory KSeF introduction deadline for all taxpayers
– The introduction of an “offline mode” available for all taxpayers during the transition period
– Regulating the issue of consumer invoices by allowing their issuance in KSeF
April 2024: Presenting the draft of legal solutions and the draft of the revised interface software specification (you can learn more from our article from April)
July 18, 2024: A summary of all the proposed changes aimed at liberalizing the terms and conditions of mandatory e-invoicing and the presentation of proposed business solutions, which included: replacing the KSeF environment with the target one, implementing attachments and updating the e-invoice structure.
Final consultations regarding KSeF – what do we know so far?
The final consultations regarding KSeF, inter alia, KSeF for SAP, will focus on the law concerning the mandatory introduction of the system, as well as the logical structures. The Ministry of Finance has announced that they will continue working on the draft law and on the proposals for business and technical solutions related to this project, while taking into consideration the need for extensive public consultations.
The obligation to use structured invoices is approaching rapidly, so it is worth taking an interest in the topic now and preparing your company for the upcoming changes. More information on the implementation of the KSeF obligation can be found on the government website.
Are you planning to integrate the KSeF system with SAP software but don’t know where to start? Take advantage of our offer, and we will help you implement the changes smoothly and ensure compliance with legal requirements.
