KSeF: new launch date and new technical challenges

KSeF – two new dates for the entry into force of e-invoicing obligation

During the conference on April 26, the Ministry of Finance announced a new schedule for the implementation of mandatory invoicing in the National e-Invoicing System (KSeF). Due to the detection of numerous errors during the audit, the system will be launched in two stages:

• 1 February 2026 - mandatory KSeF for companies with turnover above PLN 200 million per year,
• 1 April 2026 - mandatory KSeF for all other companies.

Postponing the entry into force of the new obligation is intended to ensure safe circulation of invoices in the economy. The current terrible technical condition of the system could lead to chaos in the first days of KSeF implementation.

Moreover, as the Minister of Finance assured, the delay in launching the mandatory KSeF will not negatively affect the preparatory work undertaken so far by numerous companies aimed at implementing the new system. External interfaces are expected to remain unchanged.

Audit results: numerous errors and omissions

The audit of the National e-Invoicing System (KSeF) revealed numerous irregularities, including: failure to meet quality and efficiency requirements, which forced the ministry to postpone the implementation of mandatory e-invoicing.

The main problems identified during the KSeF audit are:

• poorly designed IT architecture - low system efficiency, failure rate, security problems,
• errors and omissions in project management - improper supervision of the project, documentation kept in an opaque and disorderly manner,
• lack of response to warning signals - information about irregularities in KSeF appeared already in the first half of 2023, but there were no corrective actions.

The audit report contains as many as 350 pages, and the irregularities and errors revealed therein led the Ministry of Finance to take decisive corrective actions and appointing a team of IT architecture specialists.

Actions taken regarding KSeF include:

• complete reconstruction of the existing KSeF system architecture,
• appointing a team of IT architecture specialists,
• creation of new software consistent with the new architecture and presented recommendations.

The full KSeF audit report will not be disclosed due to the protection of the state's critical infrastructure, but fragments of the report regarding technical issues important for preparations for the implementation of KSeF will be made available to taxpayers.

Check how we can help: KSeF – support for companies

KSeF - continuation of dialogue with entrepreneurs

The Ministry of Finance decided not only to postpone the deadline for the KSeF, but also to change the legislative process regarding the KSeF, based on consultations with entrepreneurs, in which approximately 10,000 people participated.

The legislative process will be divided into two stages:

Stage I - until June 2024:

• Determining a new date for the implementation of the mandatory KSeF
• Postponement of additional deferrals regarding:

• Fines for errors in KSeF
• Payment requirement with KSeF number (without Split payment mechanism ‘MPP’)
• Invoices issued from the cash register

Stage II:

• Development of detailed legislative solutions.

The Ministry of Finance also declared its willingness to continue consultations with entrepreneurs.

Find out more about KSeF: Mandatory KSeF – draft amendment to the e-invoicing act