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The draft amendment to the Polish VAT Act UD477 of 22 September 2026 introduces a significant change to the National e-Invoicing System schedule. The most important point for entrepreneurs is the postponement of the deadline for applying fines for KSeF irregularities from 1 January 2027 to 1 January 2028.
This is good news for companies that continue to adapt their processes and systems to new requirements. However, it is worth remembering that postponing penalties does not postpone the obligation to use KSeF itself. 2027 will remain an important stage in the system’s operation, and the additional time should be used to refine integration and organise internal processes.
Penalties in KSeF from 2028
Under current regulations, financial sanctions related to the KSeF were to apply from 1 January 2027. Draft UD477 postpones this deadline by another 12 months.
The penalties may include, i.a., issuing an invoice that bypasses the KSeF. The postponement is intended to give entrepreneurs greater stability during the transition and more time to resolve technical, organisational, and integration issues.
This is particularly important for smaller entrepreneurs who need more time to adapt to the new rules, as well as for companies facing technical and organisational difficulties with their own ERP systems. The additional sanction-free period is intended to make it easier to put these processes in order and prepare for the full operation of KSeF.
Lack of penalties does not mean postponement of the obligation
The postponement of sanctions does not mean a “holiday from the KSeF”. At the end of 2026, further transitional arrangements expire.
From 1 January 2027, it will no longer be possible to issue invoices using cash registers or treat receipts with a tax identification number up to PLN 450 as simplified invoices. Entities whose monthly invoiced sales do not exceed PLN 10 thousand gross will also no longer be able to issue invoices outside the KSeF.
In practice, this means that although there are no financial penalties, the obligation to use KSeF remains.
How is the Polish National Revenue Administration (KAS) expected to react in 2027?
According to the project’s assumptions, the absence of fines will not mean a lack of control.
According to the draft, tax offices will first inform entrepreneurs of the obligation to use the KSeF and call for the removal of irregularities. If this does not work, authorities can conduct checks to verify the correctness of settlements.
From an enterprise perspective, this means that the postponement of penalties should not be treated as permission to postpone integration. Invoicing issues can still affect relationships with contractors, the correctness of settlements and the efficiency of operational processes.
How to use the extra time?
The postponement of sanctions should be treated as an additional buffer to refine the process, and not a reason to stop work on the KSeF.
In the coming months, companies should focus primarily on:
- mapping of invoicing processes,
- limiting the issuance of documents outside the integrated systems,
- preparation of stable communication with the KSeF API,
- support for offline modes and certificates,
- automatic retrieval of the Official Confirmation of Receipt (UPO),
- preparing accounting and operational teams to handle new statuses and exceptional situations.
For organisations operating at scale, it will be especially important to ensure a consistent, as-central-as-possible communication process with KSeF. This makes it easier to monitor document flow, respond to errors, and reduce the number of independent integrations to maintain.
