What we know about the upcoming B2B mandate in Poland

For the past year, the status of the upcoming B2B e-invoicing mandate in Poland has been somewhat unclear. Originally scheduled for 2024, the implementation deadlines have been postponed due to the new government identifying significant flaws in the project and the future central platform known as “KSeF.”

Since then, the government has been reevaluating the situation, conducting numerous consultations, and issuing various official announcements. However, many aspects remain undefined; let’s summarize what we do know.

What we know for sure

The mandate has been pushed back to 2026, specifically:

• 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.

A central platform called “KSeF” will be established. The government has confirmed building a new version of this platform from the ground up, as the previous administration’s project encountered too many design flaws.

The mandatory e-invoice format, based on XML, will be known as “FA(3)“. It will evolve from the currently available FA(2) format.

What remains uncertain

Numerous topics are still being worked on by the government, but two key issues stand out.

First, according to government communications, the future FA(3) format is expected to introduce only minor changes to the existing FA(2) format, such as adjustments in field lengths or minor semantic modifications. However, since the FA(2) format does not comply with the European Norm (EN) 16931, there has been no information regarding whether FA(3) will address this issue. If FA(3) also lacks compliance, it could create challenges in the future, as the European ViDA directive will require member states to mandate e-reporting using EN 16931-compliant formats starting in 2030.

Then, it is still unclear whether B2C invoices will be included in the upcoming mandate, although the government appears to suggest that voluntary inclusion may be an option.

Next steps

Public consultations are ongoing, with the next session scheduled for late October / early November. Recent announcements have included the potential for adding attachments to e-invoices submitted to the KSeF, as well as efforts to align the test, pre-production, and production environments of the KSeF in order to facilitate integration with the platform. Furthermore, the FA(3) invoice format is set to be published in Autumn 2024.

Currently, there is no tentative date for the official publication of the law, but this should occur in the coming months if the government aims to meet its early 2026 deadlines. In the meantime, the KSeF official website continues to provide updates, and an official comprehensive FAQ has been published.

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