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The Ministry of Finance is preparing changes to the regulations on the use of the National e-Invoicing System. A draft regulation has been included in the list of legislative works to enable, among other things, the permanent use of tokens for authentication in KSeF.
This is a significant change from the current legal status, according to which tokens can be used until December 31, 2026.
Tokens in KSeF also after 2026
The draft regulation included in the list of legislative works under No. 138/2026 provides for permanent authentication in KSeF using tokens. They are to function in parallel with KSeF certificates.
The Ministry of Finance has already announced such a direction. The change must now be formally included in the regulations.
The project also includes:
- regulations on the collection and use of KSeF certificates depending on their purpose,
- regulations on the handling of the collective identifier in KSeF.
What does this mean for businesses?
The most important takeaway for enterprises using KSeF integration is that, at the end of 2026, there will be no need to move away from tokens in favour of certificates. This may be particularly important for organisations that use tokens in financial and accounting systems or other solutions that communicate with KSeF. However, we still have to wait for the detailed rules. The entry in the list of legislative works itself determines the direction of the changes, but does not yet determine the final wording of the regulation.
Among the proposals discussed earlier were, i.a., changes to the validity period of new tokens or the extension of possibilities related to the collective identifier – the currently used tokens, although formally indefinite, are to remain valid in the KSeF until November 30, 2027, while an expiration date will be set for newly generated ones. Until they are confirmed in official regulations, they should not be treated as binding solutions.
Collective identifier also to be changed
The planned regulation is also to regulate the use of a collective identifier, which allows one payment to be linked to multiple invoices.
This solution is particularly important for large organizations processing large volumes of documents. Exorigo-Upos postulated, i.a., the possibility of increasing the maximum number of invoices that can be covered by one collective identifier.
However, the final solutions in this regard must wait until the publication of a detailed draft of the regulations.
