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The latest draft of the Act on the National e-Invoicing System assumes that the offline24 mode will cease to be an emergency solution and become a permanent element of the system used at sellers’ discretion. Although theoretically it is intended to facilitate invoicing in situations where there is no connection to the KSeF, its introduction raises serious doubts, especially in the case of B2B transactions.
The offline24 mode allows you to issue an invoice without communication with the Ministry of Finance system, provided that the document is sent to the KSeF by the end of the next business day and the printout or PDF is provided with additional QR codes. However, this seemingly convenient solution imposes new obligations on the seller’s part: the need to verify the buyer’s status, strict monitoring of deadlines and the risk of sanctions in the event of errors. As a result, many companies require adapting accounting processes and systems.
What exactly is changing? Here are the highlights:
Offline invoice only for selected recipients
The new offline24 mode in KSeF allows you to issue an invoice without an immediate connection to the Ministry of Finance system. Until now, it was reserved only in case of a failure or lack of access to the Internet. However, the latest amendment to the VAT Act authorises taxpayers to use it freely. But beware: such an invoice can only be forwarded to the recipient if it is a natural person (B2C), a foreign contractor, an entity without a tax identification number or a taxpayer benefiting from the exemption. This is not explicitly stated in the Act. Still, according to Article 106gb(4) in domestic B2B transactions, the invoice must first go to the KSeF and receive a number before it is handed over to the customer. Otherwise, the document will not be considered to have been issued correctly.
The critical role of the sale date
If a company sends an invoice to the KSeF today with a sales date yesterday or earlier, the system automatically considers the invoice as issued offline. This also applies to cases where the intention was to issue it online, but due to the load on the systems or the lengthy approval process, the invoice was sent to the KSeF with a delay. This may result in a violation of regulations and the risk of sanctions. Therefore, companies should consider additional control mechanisms, e.g. checking the validity of the sales date when approving an invoice.
Obligation to send the invoice by the end of the next business day
Offline24 invoices must be delivered to the KSeF on the next business day at the latest. Failure to ship on time will be considered a violation of regulations and may result in sanctions. Meeting the mandatory deadline may be difficult if the invoice is rejected by the KSeF, especially in the case of stationary sales – the customer received the invoice, left the store, and the seller only finds out after some time that the KSeF rejected the invoice. For e-commerce sales, contacting the buyer (email, contact phone) is usually possible. Still, in the case of stationary purchases, only contact using the address from the invoice may be available.
The end of tokens – mandatory certificate from 2026
The current mode of authorisation in the KSeF using tokens will be in force until the end of 2026. However, if taxpayers would like to use the offline24 mode from 1 February 2026, they must prepare for an additional requirement – it will be mandatory to have a KSeF certificate. In the offline24 mode, placing a QR code on the invoice visualisation is necessary, which contains the invoice distinguishing feature (a cryptographic hash of the XML file compliant with the schema) signed with a KSeF certificate. Significantly, February 1, 2026, falls on a Sunday, and implementing the changes may be organizationally demanding. In addition, from February 2 to February 15, 2026, winter holidays will apply in the following voivodeships: Lower Silesian, Kuyavian-Pomeranian, Łódź, West Pomeranian, Lesser Poland and Opole.
Corrections and SAF-T – only after assigning a KSeF number
A correction invoice can be issued only after the original/source invoice has been registered in the KSeF. Similarly, a document can be included in the SAF-T file only after the assigned KSeF number. This means that the sales system should wait for the number and only then pass the data on – e.g. to accounting or SAF-T. This can create unnecessary discussions, if, for example, a B2B customer purchased in a brick-and-mortar store on an invoice issued offline24, after realising that he took the wrong size/colour/model, wants to return the product and get a correction. The seller replies, “I’m sorry, but I can’t issue a correction because the original KSeF invoice has not yet been assigned a number”.
The requirement of the Ministry of Finance that the correct document be entered into the system only after the original invoice has been numbered is justified because the KSeF does not provide a chronology. Otherwise, it could happen that the seller would send an invoice and then a correction, and the KSeF would first register the corrected document and then the source invoice. However, this should not prevent the seller from issuing a correction at a given time. It should limit the possibility of sending it to the KSeF before registering the source invoice.
There were supposed to be no duplicates, but they won’t leave us so soon
Suppose the buyer does not use the KSeF and loses the visualisation of the invoice. In that case, the seller must issue a duplicate: if it does not already have a KSeF number, the duplicate must contain the QR code in the offline version, and if it already has a KSeF number, the duplicate must contain the online QR code. This means that you need to track the invoice status and generate the appropriate document version.
New rules for QR codes
Each invoice, regardless of the mode, will have to contain a QR code with information about the date of sale, the seller’s tax identification number, and a unique identifier or distinguishing feature of the document. In the offline24 mode, the invoice will contain two QR codes: under one code, the inscription “OFFLINE”, and under the other code, the inscription “CERTIFICATE.”
Greater buyer verification
Companies will have to verify the buyer’s status each time (whether they have a Polish NIP or a fixed place of business in Poland) in order to correctly select the mode of issuing an invoice. In practice, there is no simple systemic way to verify contractors’ data, which results in the need to organise sales procedures properly.
When can offline mode help?
The offline24 mode gives the company a real advantage in servicing foreign customers. For example, a truck driver driving through Poland will receive a formal VAT invoice issued on the spot at a gas station. If the consumer asks for an invoice, the seller can choose between the offline24 mode, the online mode, or issuing sales documents in the current way, because B2C invoices are not mandatory in the KSeF.
The Ministry of Finance has met entrepreneurs’ expectations by introducing greater flexibility in using the “offline24” mode. However, according to the Ministry’s response to the demands made during the public consultations, further relaxation of the regulations in this area is no longer possible or planned. Even though signals have been repeatedly communicated about the needs and concerns of retail chains related to issuing invoices and corrections in the KSeF, the Ministry of Finance has unequivocally communicated that it does not envisage any further concessions.
Although technically complex, changes in the KSeF have real consequences for companies’ daily operations. The offline24 mode can be helpful in exceptional situations, but its use in B2B relations requires great caution. This is a good time to conduct an internal audit of preparation for the new rules.
We encourage you to contact our team of specialists. We offer comprehensive technical and substantive support in implementing Smartksef, our comprehensive solution for handling electronic invoices. Contact us to learn more about our solution.
