EU · Ministerstwo Finansów / KAS
Poland
KSeF 2.0 launches in 2026 after multiple delays. FA(3) replaces FA(2). Large taxpayers from 1 Feb 2026; all VAT from 1 Apr 2026; micro-entrepreneurs from 1 Jan 2027. 11-month penalty-free soft landing.
// Phased rollout
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01 Jan 2022 · liveVoluntary KSeFOptional use of KSeF for B2B invoicing.
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01 Feb 2026 · upcomingMandatory — large taxpayersLarge VAT taxpayers must issue via KSeF 2.0.2024 gross sales > PLN 200 million
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01 Apr 2026 · upcomingMandatory — all VATAll other VAT-registered taxpayers.
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01 Jan 2027 · upcomingMandatory — microSmallest taxpayers join KSeF.Monthly turnover < PLN 10,000
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01 Jan 2027 · upcomingPenalties beginEnd of soft-landing grace period.
// Penalties
Up to 100% of VAT shown on the invoice or 18.7% of total invoice amount; suspended until 1 January 2027.
// ERP implementation notes
SAP S/4HANA (incl. DRC) & SAP ECC
SAP DRC Poland: PL_INVOICE eDocument scenario for KSeF 2.0; FA(3) generation; mTLS authentication via SAP CPI.
Microsoft Dynamics 365 (F&O + Business Central)
D365 F&O Poland ER for FA(3); Electronic invoicing service connects to KSeF 2.0 API.
Odoo (Community + Enterprise)
l10n_pl_edi_ksef supports FA(3) and KSeF 2.0 token-based auth.
// Frequently asked questions
What's the KSeF status — is it live yet?
KSeF (Krajowy System e-Faktur) has been live as a voluntary system since 2022. Mandatory rollout was originally scheduled for July 2024, then deferred multiple times. Current target: 1 February 2026 for businesses with turnover > PLN 200M, and 1 April 2026 for all other taxpayers. Verify the latest deferral status with the Ministry of Finance.
FA(3) versus older versions — what changed?
FA(3) is the current KSeF schema (the third major iteration). Compared to FA(2) it adjusts field requirements, adds support for specific transaction types (factoring, split payment marking), and tightens validation. If your integration is on FA(2), plan an upgrade — the Ministry has confirmed FA(3) for the mandatory go-live.
What's distinctive about KSeF as a clearance model?
It's a true clearance: every invoice is sent to KSeF, validated, assigned a KSeF number, and the customer fetches it from KSeF (not from the supplier directly). This makes KSeF the system of record. Off-network 'email a PDF' workflows become non-existent for in-scope transactions.
Which ERPs have native KSeF connectors?
SAP DRC Poland is the most mature; Oracle Fusion via Tax Reporting Cloud + Polish localisation; Microsoft Dynamics 365 F&O with Polish localisation; Comarch ERP (large Polish market share) has native KSeF; Sage Symfonia (popular in Polish SME). Odoo and Zoho have functioning modules. SAP ECC needs third-party middleware.
Do we need a Polish entity to register on KSeF?
You need a Polish NIP (tax identification number). Foreign entities VAT-registered in Poland can use their Polish VAT number; entities without a Polish presence cannot directly invoice through KSeF and must rely on the buyer's mechanism.
What's the consequence of an invoice not being on KSeF post-mandate?
It's not a valid VAT invoice. Buyers cannot claim input VAT on invoices that didn't go through KSeF. This creates strong incentive throughout the supply chain — your buyers will reject non-compliant invoices because their VAT recovery depends on it.