27 May 2025

KSeF 2.0 – summary of information before system implementation

The abbreviation “KSeF” (or KSeF 2.0) refers to the National e-Invoice System, which is a mandatory nationwide initiative established by the Ministry of Finance. This system allows entrepreneurs to issue structured invoices using a standardized template. Its primary goal is to digitize and simplify the invoicing process in business transactions.

A structured invoice uses a consistent format for all users, specifically XML. This uniformity enables the automation of processing by accounting systems. The Ministry of Finance provides an XML invoice template on its website, ensuring quick access to both information and the template itself.

In April of this year, the Ministry of Finance published a new schedule for the nationwide implementation of the KSeF system, commonly known as KSeF 2.0.

Current KSeF implementation schedule

• From 1 February 2026 – the obligation will cover large taxpayers who achieved sales exceeding PLN 200 million gross in 2024,
• From 1 April 2026 – the obligation will be extended to other entrepreneurs, except the so-called “digitally excluded” smallest companies that:
  • issue invoices up to PLN 450,
  • achieve a monthly turnover of up to PLN 10,000,
  • for them, the obligation will enter into force on 1 January 2027.

It is worth remembering that as part of the first date, February 1, 2026, the trade in KSeF 2.0 structured invoices will be launched, therefore such invoices will already be sent to contractors who are theoretically covered by the KSeF obligation later. It is worth preparing your systems in advance.

XML structured invoice

After analyzing the legal and technical aspects related to the mandatory implementation of the National e-Invoice System, the Ministry of Finance has made available a working version of the new logical structure of FA(3). This version was published on May 8, 2025, and was created based on:

• opinions submitted as part of tax consultations,
• suggestions presented during meetings with representatives of entrepreneurs’ organizations, accountants, auditors, and the IT industry.

FA(3) new structure will come into force on February 1, 2026, replacing the previously used version of FA(2). In the future, FA(3) will be published as an official electronic document template on the ePUAP platform.

In addition, supplementary materials have been published to support users in using the new structure.

KSeF – voluntary phase still ongoing

The obligation will apply to all VAT payers registered in Poland, including foreign companies with a permanent place of business in the territory of the country and issuing invoices here.

During the transition period, from January 1, 2022, to the end of 2025, the use of the National e-Invoice System (KSeF) is voluntary. During this time, entrepreneurs can adjust their accounting systems and train their staff.

KSeF 2.0?

The Ministry’s plans for June this year include the release of information regarding the new, updated version of KSeF, known as KSeF 2.0. This update will provide detailed data alongside a template for the new logical structure of FA(3), documentation for the programming interface (API), and the specifications for the interface software. Additionally, the KSeF Taxpayer Application is currently available to users as part of the voluntary phase of the system’s implementation. You can find the download link in the “useful links” section below.

KSeF 2.0 – useful links

• https://ksef.pl/ – home page with a collection of the most important information about KSeF
• https://www.gov.pl/attachment/34b3d81d-1fb8-4832-9155-3b1594d0c277 – presentation on the KSeF implementation plan
• https://ksef.podatki.gov.pl/aplikacja-podatnika-ksef-i-inne-narzedzia/ – information on the KSeF Taxpayer Mobile Application (demo and production versions)
• https://ksef.podatki.gov.pl/media/ukrllh1e/schemat_fa_vat-3-_v1-0.xsd – logical structure of FA(3) (XML)