Poland Finalizes KSeF Implementation:
Executive Regulations Signed

The Polish Minister of Finance and Economy has officially signed four executive regulations regarding the operation of the National e-Invoicing System (KSeF). These regulations clarify usage rules, exemptions from the structured invoicing mandate, and the new data requirements for JPK_VAT declarations.
Key Highlights of the Regulations:

• Exemptions from E-Invoicing: Highway tolls, passenger transportation tickets (train, bus, etc.), air traffic control services, and VAT-exempt financial/insurance services will not be required to issue structured invoices via KSeF due to technical constraints.
• Simplified Invoices: Starting February 1, 2026, simplified invoices issued within KSeF must include the seller’s Tax ID (NIP). This requirement will not apply to B2C invoices issued outside the system.
• System Access and Authentication: Procedures for granting access (including the ZAW-FA form), authentication methods via certificates, and technical requirements for issuing invoices with attachments have been established.
• JPK_VAT Integration: For reporting periods starting February 1, 2026, the unique KSeF identification number must be included in VAT records. New markers such as “OFF” (offline mode), “BFK” (paper/electronic invoices), and “DI” (other documents) will be introduced for non-system entries.
• No Automatic Penalties: Penalties for incorrect JPK filings will not be automatic. Taxpayers will have the opportunity to correct errors following a notice from the tax authorities.

Official Polish Ministry of Finance regulations for the National e-Invoicing System