KSeF mandate: who it covers and which invoices are excluded

Choose who the invoice is for and how you issue it. The tool says whether it must go through KSeF, may, or must not be sent there at all.

Year issued

This invoice

Optional

No obligation; you may issue it in KSeF if you wish.

Counts towards the PLN 10,000 limitno
QR code on a printout or PDFno
Storage in KSeF10 years

Basis: Art. 106gb of the VAT Act, regulation 2025 item 1740, Ministry page on the scope of mandatory KSeF.

How this is calculated

Prepared by Radif Partners · Method · VAT Act, regulations and ministry notices checked on 25 October 2026

The KSeF obligation comes from Article 106ga of the Polish VAT Act and applies to taxpayers whose business is established in Poland or who have a fixed establishment there that takes part in the sale. It covers invoices to businesses, including foreign ones: an invoice to a buyer abroad is issued in KSeF and handed over in an agreed way, with a QR code. Invoices to consumers may be issued in the system but need not be. Invoices under the non-Union OSS and IOSS schemes, invoices for occasional passenger transport by coaches registered outside Poland and invoices under the EU SME scheme of Article 113a must not be sent to KSeF. Regulation 2025 item 1740 excludes, among others, single tickets and motorway tolls issued as simplified invoices, exempt financial and insurance services on such invoices, and self-billing by a buyer without a Polish tax ID; these invoices stay outside the system. Pro forma invoices and notes are not invoices, so they never go to the system. Until 31 December 2026 cash-register invoices also stay outside KSeF.

Must, may, must not

Under the VAT Act and regulation 2025 item 1740
InvoiceKSeFBasis
to a business with a Polish tax IDmustArt. 106ga(1)
to a business abroadmust, handed over outsideArt. 106gb(4)
to a consumermayArt. 106gb(4)(6)
from a cash register, receipt with tax IDoutside KSeF until 31 December 2026Art. 145n
seller with no seat or fixed establishment in PolandmayArt. 106ga(2)
non-Union OSS, IOSSmust notArt. 106ga(2)
EU SME scheme, Art. 113amust notArt. 106ga(2)
occasional passenger transport from abroadmust notArt. 106ga(2)
single ticket, motorway toll, exempt financial service (simplified invoice)outside KSeFregulation item 1740, § 2
pro forma, debit notenot an invoice-
VAT RRmay, since 1 April 2026FA_RR

The exclusions in Article 106ga of the VAT Act are a closed list: if your invoice is not on it and the buyer is a business, the invoice goes to KSeF. Further cases of invoices issued outside the system are listed in regulation 2025 item 1740; only self-billing of an intra-EU supply by a buyer with an EU VAT number may go to KSeF voluntarily.

Seat and fixed establishment

The duty depends on where the issuer is. A business established in Poland always issues in KSeF. A foreign business has the duty only when its fixed establishment in Poland takes part in the sale. That assessment needs the facts, which is why the tool shows it as a separate option, and the ministry covers it on the page on the scope of the obligation.

Once the duty applies to you

Check the date for your business and whether you fit the transitional limit:

KSeF invoices mandatory from

KSeF invoices mandatory from

1 January 2027

Receiving invoices in KSeFsince 1 February 2026
PLN 10,000 monthly limitapplies until 31 December 2026
Receipt with tax ID, cash-register invoiceoutside KSeF until 31 December 2026
Penalties under Art. 106nifrom 1 January 2027 (law); bill: 1 January 2028
Check when you issue in KSeF →

An invoice to a foreign business or a consumer handed over outside the system needs a QR code; the rules are on the QR code page. How the buyer receives an invoice and from when it counts as received is explained under what KSeF is. The dates of every stage are in the KSeF calendar.

Examples from practice

A Polish business selling to Czechia. It issues the invoice in KSeF, because it is established in Poland, and emails it to the Czech buyer with a QR code. A German carrier with no branch in Poland. It has no obligation but may issue invoices in KSeF voluntarily. An online shop selling to consumers. Invoices to private customers need not go to the system; when a business with a tax ID buys, the invoice goes to KSeF. A motorway toll or rail ticket. A simplified invoice in the form of a ticket stays outside the system.

When an invoice covers several different supplies, the channel depends on the buyer and how the invoice is issued, not on the type of goods. When in doubt, it is better to issue in KSeF, unless the rules forbid it, than to risk an invoice outside the system.

The list of exclusions is short, so for most businesses the answer is simply that business invoices go to KSeF. The tool above lets you check unusual cases one by one before you set up your invoicing software.

Common questions

Must an invoice to a German company be issued in KSeF?

Yes, if you are established in Poland. An invoice to a buyer with no seat or fixed establishment in Poland is issued in KSeF, but the buyer does not collect it from the system. You hand it over in an agreed way, for example by email as a PDF with a QR code that lets the buyer check the invoice in KSeF.

Must a foreign company registered for Polish VAT use KSeF?

Only if it has a fixed establishment in Poland that takes part in the sale. VAT registration alone is not enough. A taxpayer with neither a seat nor such a fixed establishment may issue in KSeF voluntarily. Whether a fixed establishment exists can be disputed, so when in doubt it is worth asking an adviser.

Does a pro forma invoice go through KSeF?

No. A pro forma is an offer or a request for payment, not an invoice under the VAT Act, so it is not sent to the system. The same goes for debit notes. Correction notes disappeared in February 2026: an error on a KSeF invoice can be fixed only by the issuer, with a corrective invoice.

Must a VAT RR invoice for a flat-rate farmer go to KSeF?

No. Since 1 April 2026 VAT RR invoices may be issued in KSeF voluntarily, in a separate FA_RR structure. This needs the farmer’s consent and access to the system on their side. Those who do not use it keep issuing VAT RR invoices as before, on paper or electronically outside the system.

Keep going

Official sources for this page

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