Poland – KSeF Update: Revised Legislation Coming in Q2 2025

1.Ministry of Finance Responds to Stakeholder Feedback from November 2024 Consultations 

In response to a recent parliamentary inquiry, the Polish Ministry of Finance (MoF) has shared a formal update on the status of the National e-Invoicing System (Krajowy System e-Faktur – KSeF). The Ministry emphasized that work on the system continues as a high priority and that the legal and business feedback submitted during the November 2024 public consultations is currently under thorough review. 

2. New Draft Legislation to Be Submitted in Q2 2025 

The revised draft law, originally scheduled for publication in Q1 2025, is now expected to be submitted to the Council of Ministers in Q2 2025. If necessary, the MoF may conduct an additional public consultation round before the legislation proceeds to the Sejm (the lower house of the Polish parliament) for debate and approval. 

3. Mandatory KSeF Rollout Dates Remain Unchanged 

Despite delays in legislative drafting, the Ministry reaffirmed its commitment to the current timeline for mandatory e-invoicing: 

• February 1, 2026 – for large taxpayers 

• April 1, 2026 – for all other taxpayers 

There are no plans to postpone these go-live dates. 

4. Information Campaigns Planned to Support Businesses 

To support smooth implementation, the Ministry will launch nationwide information campaigns. These efforts will aim to educate taxpayers, clarify compliance requirements, and guide businesses in their transition to KSeF. 

5. Status and Role of the FA(3) XML Schema 

Although the Ministry addressed the legislative timeline, it did not provide any update on the release date of the FA(3) XML schema, which is eagerly awaited by businesses and software providers. 

The FA(3) schema is the next planned version of the structured XML format used for submitting e-invoices to KSeF. It defines the technical specifications, data fields, validation logic, and structure required for invoice acceptance. 

• Currently, the FA(2) schema remains in use under the voluntary phase of KSeF. 

• FA(3) is expected to introduce enhancements aligned with the revised legal framework and will likely become mandatory in advance of the February/April 2026 enforcement dates. 

• Until further notice, stakeholders should continue using FA(2) and monitor official communications for FA(3) schema publication.