Poland Proposes Changes to KSeF Token Rules and New Payment Permission
On October 27, 2026, Poland’s Ministry of Finance and Economy published draft regulation No. 138/2026 opening a public consultation on changes to authentication tokens and access permissions within the KSeF (Krajowy System e-Faktur) national e-invoicing system. The proposals remain subject to consultation and adoption.
Proposed Token Validity Rules
- Tokens generated from January 1, 2027, would be valid for up to 365 days, counted either from creation or from a start date set by the taxpayer.
- Tokens created before that date would remain valid until November 30, 2027.
Certificates and Peppol
The draft includes new arrangements for entities using the Peppol network and sets new validity limits and further rules for KSeF certificates. It would also allow certificate holders to generate a certificate limited to a specific Polish tax identification number (NIP) or a branch identifier, which can help service providers manage access separately across several clients; the certificate’s practical reach would still depend on the permissions held by the holder.
New Collective Payment Identifier Permission
The draft introduces a new permission that allows users to create, decode, search for, and view identifiers linking a single payment to multiple invoices, which is relevant to the obligation to quote KSeF numbers in payments between active VAT taxpayers from January 1, 2027. This permission can be granted separately from invoicing permissions, for example, to an employee who handles payments but does not issue invoices.
Effective Dates
Most of the proposed amendments would take effect on January 1, 2027. The token-validity extension would take effect on December 31, 2026, subject to completion of the legislative process.
There’s more you should know about e-invoicing in Poland – learn more about the new and upcoming regulations.
