Following the postponement of the B2B e-invoicing mandate initially set for early 2024 by the previous administration, the Polish government has taken a proactive approach in communicating about the revised mandate.
The Ministry of Finance (MoF) has held several public consultations to address concerns with the original plan. After the most recent discussions in October, a range of adjustments are now proposed to support companies in transitioning to the new requirements nationwide.
A final public consultation is being conducted this November, with the goal of publishing the legislation in Q1 2025. The deadlines for mandatory e-invoicing in 2026 have also been confirmed: February 1st for large companies and April 1st for all other companies.
Key Changes
- Grace Period: No penalties will be imposed until July 31, 2026.
- Extended Grace Period for Very Small Companies (with low turnover and invoice amounts): These companies are exempt from the mandate until September 30, 2026.
- KSeF “Offline” Mode: Available until December 31, 2026, allowing companies to submit invoices to the KSeF up to one day after issuance.
- Attachments: Companies can now add attachments to invoices submitted to the KSeF.
More changes have been revealed (B2C, cash registers, payments, …): read the full announcement on the MoF website.
Additionally, the specifications for the FA(3) invoice format are now available.
Proposed Timeline
Crucially, the government has confirmed that the mandate deadlines will stay unchanged:
- From February 1, 2026:
- All companies across the country must be capable of receiving electronic invoices that meet the mandate’s requirements.
- All companies with an annual turnover exceeding 200 million PLN (~46 M€) must also issue such electronic invoices.
- From April 1, 2026:
- All companies nationwide must send e-invoices.
The MoF is also targetting the following intermediate timeline:
- November 2024 (current): Final round of public consultation
- Q1 2025: Law vote and publication
- June 2025: Publication of KSeF API documentation
- September 2025: Start of the KSeF public test phase
- November 2025: KSeF platform available in production
For more details on the upcoming mandate, check out our Poland country profile and follow The Invoicing Hub on LinkedIn to stay updated.
