The Polish Ministry of Finance has released a revised draft regulation for the National e-Invoicing System KSeF. The update clarifies existing provisions on certificates, QR codes, and attachments, while keeping the overall approach and timelines unchanged. For context on the KSeF mandate and the planned switch to 2.0, see our earlier overview here.
KSeF 2.0: what the updated draft includes
The Ministry of Finance has published an updated version of the draft regulation governing the use of KSeF. The document addresses technical and operational aspects such as authentication, user rights, certificate handling, invoice marking with QR codes, and the use of attachments. These topics build on the direction set out in our previous blogpost on the KSeF 2.0 transition about the mandate and 2.0 switch.
Unlike earlier drafts, this version does not bring major changes. Instead, it improves clarity by refining definitions and providing more precise explanations of existing mechanisms. The overall structure and deadlines for KSeF remain unchanged, in line with the expectations outlined in our earlier update.
Key clarifications for companies
KSeF certificate validity
Certificates are valid for up to two years from the creation date or from a starting date chosen by the taxpayer. Renewal during the validity period remains possible.
KSeF certificate functions
The draft provides a clearer description of certificate purposes:
- Authentication in the KSeF system
- Confirmation of issuer identity when invoices are issued in special modes
Invoice marking with QR codes
Invoice marking requirements now differ depending on when the invoice is shared with the buyer:
- Before submission to KSeF: invoices must include both an access QR code and a certificate QR code.
- After submission to KSeF: only the access QR code is required.
Attachments process
The updated draft refines procedures for notifying and submitting invoices with attachments, ensuring consistency in how these are managed within KSeF.
Next steps
The draft regulation is still under review by the Ministry of Finance and has not yet been finalized. Businesses operating in Poland should follow developments closely and prepare for adjustments once the regulation is approved. For a broader view of expected timelines and the migration path to KSeF 2.0, revisit our earlier post on the KSeF mandate and 2.0 switch.
Key takeaways
- Prepare for two year certificate validity cycles.
- QR code requirements vary depending on invoice timing.
- Attachment handling procedures are more structured and should be built into compliance processes.
