What is KSeF and what are Poland's e-invoicing mandate requirements?
KSeF (Krajowy System e-Faktur, or National e-Invoice System) is Poland's centralized e-invoicing platform operated by the National Revenue Administration (KAS). KSeF mandates that all Polish VAT-registered taxpayers issue structured e-invoices (FA(2) XML schema) through the KSeF platform, which assigns each invoice a unique KSeF number and stores it centrally. The mandate became mandatory for large taxpayers in 2024 with broader rollout phased.
How does invoice issuance work in KSeF?
KSeF issuance workflow: (1) Taxpayer generates invoice in the FA(2) XML schema; (2) Invoice is submitted to KSeF via API (token-based authentication); (3) KSeF validates the schema and taxpayer's authorization; (4) KSeF assigns a unique KSeF number and timestamps the invoice; (5) KSeF stores the invoice and notifies the recipient; (6) The KSeF number is the legal reference for the invoice. Buyers access invoices from their KSeF inbox rather than receiving files from the supplier. KSeF ID replaces the invoice number as the primary document identifier for VAT deduction purposes.
Frequently Asked Questions
- What is the FA(2) schema in KSeF?
- FA(2) is the mandatory XML schema for KSeF e-invoices, published by the Polish Ministry of Finance. It is based on a national schema that must contain all mandatory VAT invoice fields under Polish law plus KSeF-specific extensions. FA(2) does not use UBL or CII; it is a bespoke Polish schema. Suppliers must ensure their ERP or invoicing software can generate FA(2)-compliant XML.
- What are the penalties for non-compliance with KSeF?
- Non-compliance with KSeF will result in financial penalties: failure to issue an invoice through KSeF when required may result in a fine of up to 100 percent of the VAT shown on the invoice, and at minimum 50 percent of the VAT amount. Additionally, buyers cannot deduct input VAT on invoices not issued through KSeF (once the mandate applies). Penalty enforcement is expected to be phased in alongside the technical mandate.