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There are only a few days left until the obligation to use KSeF for the largest companies takes effect, and market signals may raise concerns. Exorigo-Upos reports show that the priority of KSeF implementation has fallen from 66 percent in 2023 to 38 percent in 2025 among companies, which, in light of recent public declarations by the largest retailers, paints a picture of a market full of concerns. Entrepreneurs, despite completed tests and support from IT suppliers, face questions about the maturity of their processes, data quality, and the real risk of operational paralysis at the start of the system.
The observed decline of KSeF in the hierarchy of the most important investments (from 1st to 5th place in two years) may suggest that many organizations have already passed the stage of the biggest technological changes. For 44 percent of respondents, implementation has become an issue that “can wait”, which, however, in the face of the inevitable deadline of 1 February, raises questions about the real state of preparations in the event of failures or validation errors.
This situation is particularly evident in the retail sector, where the reluctance to speak publicly about operational readiness shows the scale of uncertainty. Companies are concerned not only about the instability of the ministerial infrastructure, but also about how KSeF will affect their relationships with contractors. The key challenge remains whether the possible failure of some suppliers to prepare will lead to chaos in supply chains and invoicing errors, which are identified as one of the most serious risks of the transition period.
– The current restraint in the declarations of many companies is not a lack of preparation, but an expression of mature caution before implementing a solution of such a large scale. KSeF is not just a simple interface for sending documents, but an open-heart operation for ERP systems and logistics processes. Companies that view this obligation as part of a broader digital strategy can eliminate manual processes and strengthen transparency in their relationships with contractors. The key to success after February 1 will not be the technical connectivity itself, but how efficiently the organization can manage information in the new digital standard, turning regulatory obligations into real business and operational value, says Michał Sosnowski, Business Development Director at Exorigo-Upos.
SMEs must be ready in advance
It is worth noting that February 2026 is a key inflection point for the entire market, not just the largest entities. Although medium-sized and smaller companies have until April 2026 to complete mandatory implementation, in practice the system will cover them much earlier. Any company that issues an invoice to a large contractor or receives a document from it will interact with KSeF as early as February. This network of business interconnections makes the readiness of the largest players determine the pace of digitization of their smaller partners.
– Our clients are rightly afraid that the failure of some contractors to prepare will become a real risk at the start of KSeF. Large enterprises, which are required to implement immediately, contrast with smaller companies, which still assume they have plenty of time to do so, creating supply chain disruptions. From the beginning, we signaled the need for early preparation, regardless of the order of duties, to avoid losing key business partnerships, adds Michał Sosonowski.
Companies vs. KSeF – what challenges do they face?
Exorigo-Upos experts, based on the implemented work, identify five key areas that determine the success or failure of the new system. The first is the feasibility of testing. MF test environments often do not fully reflect the dynamics of everyday work, so it is crucial to use tools that allow for one-to-one simulation on real data without sending it to KSeF. Another challenge is substantive validation. KSeF checks the technical correctness of the XML file but does not assess whether business data, such as the order number or the goods description, are consistent with the arrangements with the contractor. The lack of additional control before shipment can lead to mass rejections of invoices by recipients, despite their formal correctness in the ministerial system.
Equally important is to be prepared for emergencies and chaos in distributed environments. In large organizations, invoices come from many sources: POS, ERP or WMS systems. Without a central document management system (the so-called hub), the risk of duplicates and accounting errors increases exponentially. Experts also point to specific technical challenges, such as QR codes in the 2.0 standard. Currently, scanning these codes may return a “Not Found” message because full backend support will not begin until February. This requires companies to develop transition procedures and clear communication with contractors to avoid misunderstandings at the beginning.
Technical break at the end of the implementation
The closer to the mandatory KSeF launch, the clearer it is that the final days before implementation will be the most challenging stage of the process for many companies.
– Many of our clients are concerned about the organizational chaos that accompanies this obligation from the beginning and may accompany implementation,” says Sosnowski. And this is hardly surprising, because every such a big change has a direct impact on process planning, work organization and operational decisions made in companies.
An additional challenge will be the technical outage of the KSeF 1.0 system, planned by the Ministry of Finance, which will last from 26 to 31 January 2026. The break is necessary to complete the implementation of the target version of the system – KSeF 2.0 – which, according to the schedule, will launch on February 1, 2026, and will be the only solution in force from that date. With its launch, the current KSeF 1.0, including the Certificate and Authorizations Module, will cease to function. During the technical break, only basic licenses can be applied for using the ZAW-FA form. From January 28, entrepreneurs will gain access to KSeF 2.0 verification services in the production environment. Full authorization granting and certificate application submission will resume only after the new system version is launched.
As the cut-off date approaches, the retail market is divided into two camps: optimizers, who are already reaping the benefits of automation, and observers, hoping for a smooth transition through implementation. The final verification will take place soon, and its results will define the standards of transparency and modernity in Polish business and the pace of digital transformation across the entire retail sector in the coming years.
