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Attachments to the invoice can only be sent in XML format. The QR code will be an obligatory element of the invoice, and the visualization of the invoice may differ from the Ministerial one, as long as it contains all the obligatory data. On December 23, 2024, the Ministry of Finance published a significant update of questions and answers on the National e-Invoicing System (KSeF) on the KSeF website. Below are the highlights of this update.
Invoice attachments
Format and structure: Attachments can only be sent in XML format as part of the invoice (FA structure node). It is not possible to add files in unstructured formats (np. PDF, JPG). Such documents can only be transferred outside the KSeF.
Voluntary submission: Adding attachments to invoices is optional. The attachments will be available to all taxpayers, although they are planned mainly for industries issuing invoices containing complex data.
Mandatory use of the KSeF
Implementation dates: The launch of the mandatory KSeF on 1 January would interfere with numerous reporting obligations. Therefore, the mandatory use of the KSeF will start on 1 February 2026 for taxpayers with a turnover of more than PLN 200 million in 2025. Other taxpayers will be subject to the obligation from 1 April 2026. The postponement of the mandatory KSeF deadline (e.g. for taxpayers with a turnover of less than PLN 200 million in 2025) applies only to issuing invoices and not collecting them in the KSeF. The phased implementation results from the recommendations from the system audit.
Low-value invoices: During the transitional period, invoices with a value below PLN 450 (up to PLN 10,000 per month) may be issued outside the KSeF, e.g., in paper form or PDF. However, in the long run, all invoices must be issued.
New Logical Structure (FA(3))
Planned changes: To ensure system stability, the FA(3) structure will be implemented before February 2026. The changes include, among others, adding an “Attachment” node for invoices containing additional data.
FA(1) structure issues: The “FaRows” grouper has been removed, simplifying XML generation and reducing errors.
Technical support and integration with KSeF
Test and production environments: Use a demo and test environment for testing. Sending invoices to the production environment has tax consequences (e.g., the need to issue a correction invoice if the test invoice was incorrect).
Tokens and certificates: For greater security, authentication tokens will eventually be replaced by certificates.
Technical support: The system’s technical documentation is available on the KSeF website. A technical hotline will be launched at the beginning of 2025.
Safe and offline modes
Offline mode: The ability to issue invoices offline will be available during the transition period and in the event of an outage. In addition to the offline mode, taxpayers issue invoices in real time
Information about failures: An independent service will be implemented to inform about the system’s status (e.g., the occurrence and completion of failures).
Invoice data and functionalities
Additional information: Fields such as “SupplementaryDescription” allow you to include details about the transaction (e.g., meter number for utility providers).
Invoice visualisation: An invoice visualization can differ from the official template of the Ministry of Finance as long as it contains all the required data. The verification code (QR code) will be a mandatory element of the visualization of e-invoices (QR codes are planned to be made available in the production medium in November 2025)
Accompanying documents: Documents such as waybills or photos are not handled by the KSeF and must be sent outside the system.
Security and anti-fraud
Anti-fraud mechanisms: The system will be equipped with technical solutions that enable the identification of suspicious invoices and the reporting of such events.
Access to the KSeF: Authorizations in the KSeF can only be granted to natural persons or entities. Permissions cannot be granted to the system.
Support for entrepreneurs
Implementation manual: The Ministry of Finance is working on creating a manual for companies that will explain the key aspects of KSeF implementation.
Technical and training support: To help companies integrate ERP systems with KSeF, webinars and the publication of detailed technical specifications are planned.
Integration with other systems
KSeF and PEF integration: KSeF is already connected to the Electronic Invoicing Platform (PEF) on a test medium.
Servicing VAT groups and foreign entities: KSeF supports entities operating within VAT groups and prepares solutions for foreign entities issuing invoices on behalf of Polish enterprises. In the case of employee purchases, the so-called internal identifier (Entity3 element) can be used to identify the employee making the company purchase.
We recommend reading all the FAQs on the KSeF website.
In addition, 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.
