Poland Finalizes Legal Framework for Mandatory KSeF 2.0

On December, 2025, the Polish Minister of Finance and Economy officially signed the regulation on the use of the National e-Invoicing System (KSeF), one of the four executive regulations for the system that were signed this month. Currently awaiting final publication in the Journal of Laws, this regulation serves as a critical implementing act for the mandatory KSeF 2.0 framework, replacing the 2021 voluntary-period guidelines.

Scope of the Regulation

The regulation provides the detailed operational rules necessary for businesses to navigate the KSeF environment:

• Permissions and Authorizations: It defines specific permission types for system access and outlines the formal procedures for granting or revoking these rights, including the use of the ZAW-FA notification form.
• Authentication Methods: The act establishes several valid methods for system authentication, including electronic identification via the national node, qualified electronic signatures, qualified electronic seals, and the newly introduced KSeF certificate.
• QR Code Specifications: Two distinct types of QR codes are introduced to ensure invoice integrity:
  
  • Verification QR Code: For invoices shared outside the system, allowing recipients to verify the document's existence in KSeF.
  • Offline Mode Signature: Used in offline mode to confirm the issuer's identity via the KSeF certificate before the invoice is formally submitted to the system.
• Invoices with Attachments: The regulation sets out the technical requirements and notification procedures for issuing invoices that include additional structured data. As a reminder, in KSeF 2.0, attachments are not separate files (like PDF or Excel) but integral XML structured data nodes embedded within the FA(3) schema.

Refinements from the Draft Version

Several key adjustments were made to the final text following the November 2025 draft to improve clarity and functionality:

• Attachment Criteria: The “complex data” requirement for using attachments is now embedded directly within the regulatory definition.
• Expanded Permissions: Authorizations for self-billing and VAT RR invoices have been explicitly expanded to include natural persons and coverage for offline or failure mode scenarios.
• VAT RR Implementation: A new provision confirms that VAT RR invoicing functionality will officially apply from April 1, 2026.
• Notification Clarification: The regulation clarifies that an existing authorized person's rights must be revoked before a new individual can be designated via the ZAW-FA form.

Implementation Timeline

The regulation introduces a phased approach to various technical requirements:

• January 1, 2026: Taxpayers may begin submitting notifications to issue invoices with attachments.
• February 1, 2026: The main regulation takes effect, aligning with the KSeF 2.0 national rollout.
• March 31, 2026: Last day Trusted Profile can be used for KSeF authentication.
• April 1, 2026: National node authentication becomes available, and VAT RR provisions take effect.
• January 1, 2027: Tokens can no longer be used for KSeF authentication purposes.

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