On 1 January 2027, Poland closes the last gap in its state invoicing system KSeF: from then on, businesses with very small invoice volumes also have to invoice through the platform. At the same time, the Polish Ministry of Finance has announced that penalties will be postponed by another year. What this means — including for businesses in Germany that trade with Poland.
As of 15 October 2026. The postponement of penalties is a draft law, not yet law in force.
The stages of the KSeF mandate
| From | Who is affected |
|---|---|
| 1 February 2026 | Businesses with more than PLN 200 million (Polish Złoty) in turnover in 2024 |
| 1 April 2026 | All other businesses registered for VAT in Poland |
| 1 January 2027 | Also those who were previously covered by the small-amount exemption |
The exemption that expires at the end of the year: anyone issuing invoices worth no more than PLN 10,000 gross per month was still allowed to invoice outside KSeF in 2026. From January, the system applies without this threshold.
How KSeF differs from the German e-invoice
In Germany, the e-invoice is a file format: you create a ZUGFeRD or XRechnung file and send it yourself, for example by email. In Poland, KSeF is a clearance platform. The invoice goes to the state platform, is accepted there and receives a KSeF number — only then does it legally exist. The format is a separate Polish XML schema, not ZUGFeRD and not XRechnung.
This makes Poland one of the countries with the strictest model in the EU. How other countries handle it is described in E-invoicing mandates in Europe.
Penalties: announced from 2028
Originally, fines for violations of the KSeF mandate were to apply from 1 January 2027. On 16 September 2026, the Polish Ministry of Finance announced that this deadline would be extended to the end of 2027; the draft bears the reference UD477. As long as it has not been passed, the old date formally applies.
Important: a postponed penalty is not a postponed obligation. From 1 January 2027, invoicing must go through KSeF; the Polish tax authorities have announced that they will pursue violations even without fines.
What this means for businesses in Germany
- You supply to Poland: The KSeF mandate applies to taxable persons established in Poland. Without an establishment in Poland, you continue to invoice under German law — for B2B customers in the EU, that means an invoice according to EN 16931, for example in the EN 16931 profile of ZUGFeRD.
- You buy in Poland: Your Polish suppliers work with KSeF. If in doubt, ask in what form you will receive the invoice, and check incoming files before you book them.
- You have an establishment in Poland: Then KSeF applies to its sales — that is a matter for your Polish tax adviser.
Frequently asked questions
Can I submit a ZUGFeRD invoice to KSeF?
No. KSeF requires its own Polish XML schema. ZUGFeRD and Factur-X follow the European standard EN 16931; the Polish schema does not.
As a German supplier, do I have to invoice my Polish customer through KSeF?
Not without an establishment in Poland. The obligation is aimed at taxable persons established there.
Does the postponement of penalties already apply?
Not yet. It has been announced and presented as a draft; until it is passed, 1 January 2027 applies.
Can E-Rechnung Pro create KSeF invoices?
No. We create ZUGFeRD and Factur-X and check ZUGFeRD, Factur-X and XRechnung. For KSeF you need software that is connected to the Polish platform.
In short
- From 1 January 2027, the last exemption in Poland falls away: KSeF also applies to the smallest invoice volumes.
- The invoice only exists once KSeF has accepted it; the format is Polish, not EN 16931 ZUGFeRD.
- According to a draft from September 2026, penalties are only to apply from 2028 — the obligation remains.
- For German suppliers without an establishment in Poland, nothing changes.
Do you invoice to Poland or other EU countries? An invoice according to EN 16931 works across borders — Create an e-invoice, free until 31 December 2026.
E-Rechnung Pro creates and validates documents against EN 16931:2017 — the version ZUGFeRD 2.x and Factur-X are built on today. We are following the EN 16931-1:2026 revision and will support it as the formats adopt it.