On Friday, May 30, 2025, the Polish Ministry of Finance published the latest draft of the law implementing mandatory e-invoicing in KSeF. This amendment modifies the earlier proposals from April 11, 2025, which we mentioned in ours last article on KSeF. It is crucial for entrepreneurs to prepare for mandatory e-invoicing.
In addition to the draft law, the Polish government also published two draft executive regulations and a new version of the ZAW-FA form.
Importantly, the draft law includes significant changes to the deposit system and the increased VAT exemption threshold.
What's new in the draft?
Timelines (almost) unchanged
The amendment to the regulations generally does not change the schedule. The obligation to issue invoices in KSeF is still scheduled to come into effect in two phases:
- February 1, 2026 – for taxpayers with a turnover exceeding PLN 200 million in 2024;
- April 1, 2026 – for other entrepreneurs.
However, there is a new provision: micro-entrepreneurs whose total sales value confirmed by invoices does not exceed PLN 10,000 per month will not be required to issue e-invoices during the transition period (i.e., until the end of 2026). For this group of taxpayers, mandatory KSeF has been postponed until January 1, 2027.
It is important to emphasize that postponing the mandatory e-invoicing date via KSeF for "other entrepreneurs" (April 1, 2026) and the aforementioned micro-entrepreneurs (January 1, 2027) does not exempt them from the requirement to receive purchase invoices through KSeF from the start of mandatory e-invoicing, i.e., February 1, 2026.
