KSeF in Poland on the horizon: continuity of invoicing and VAT
The implementation of the National e-Invoicing System (KSeF) is in the final stages — starting from February the actual issuance/receipt of invoices in KSeF will begin and an implementation of the new VAT reporting rules is awaited. The taxpayers are taking a comprehensive approach — covering an update of the accounting policy, as outlined on our blog [1]. February is the month of “being ready” — every entity must reach the required level of preparedness to transition smoothly into the new obligations and minimize operational and tax risks.
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New obligations also apply to VAT reporting in SAF-t
Along with the implementation of KSeF, reporting obligations under SAF-T will also change. For taxpayers filing SAF-T on a monthly basis, starting from the settlement for February 2026, each invoice issued / received by a VAT taxpayer will have to be included in the VAT records and VAT return including additional data resulting from the implementation of KSeF (for quarterly settlements — in the records for February 2026 and in the VAT return for Q1 2026).
One of the key changes is the requirement to report the KSeF number for each invoice in the SAF-T file. This means that companies must not only receive and send invoices via KSeF, but also retrieve the KSeF number assigned by the KSeF system and enter it into their VAT registers and VAT returns. For invoices that do not have a KSeF number (e.g. issued outside the system in KSeF system failure mode or received from a foreign supplier), it is necessary to mark them with an appropriate indications, such as OFF, BFK or DI.
In practice, implementing these changes may be challenging — especially for companies using multiple data sources or having complex invoicing processes. If a company is not ready, support from external experts may prove to be the only effective solution enabling reporting submission on time and thereby avoiding sanctions under the Penal Fiscal Code, or helping avoid gaps/errors in VAT reporting.
At CRIDO, we provide clients with the necessary support to prepare a complete SAF-T file under the new requirements, including:
- assistance in completing the necessary data retrieved from KSeF,
- taking over the process of preparing/submitting SAF-T based on data from various sources,
- or verification of the compliance of the prepared SAF-T in XML format with the new requirements effective as of 1 February 2026.
What if a company is not ready for KSeF by the statutory deadline?
Despite best efforts, not every organization will be able to fully prepare for the implementation of KSeF within the deadline required by the legislator. The reasons may vary: delays on the side of IT vendors, complexity of integration with ERP systems, limited staffing resources, or unforeseen technical difficulties.
In 2026, fiscal penalties will be deferred in the following circumstances:
- failure to issue a structured invoice using KSeF,
- failure to issue an invoice compliant with the invoice scheme during a KSeF outage or unavailability,
- failure to submit an invoice to KSeF within the statutory deadline after the end of KSeF system outage or unavailability (Article 106ni of the VAT Act).
However, it is important to note that the Penal Fiscal Code continues to apply in all other cases — for example, where an invoice or receipt is not issued, is issued incorrectly, or is refused to be provided.
If a company is not ready to implement KSeF by the statutory deadline, it is crucial to take steps that minimize the risk of penalties and ensure business continuity. In particular, it is worth:
- documenting actions taken — preparing a so-called “defence file”, i.e. documentation confirming that the company took real steps toward implementing KSeF, including software orders, implementation schedules, correspondence with vendors, and showing that the delay in implementing KSeF and preparing the organization does not result from the fault of the management board / CFO / CEO,
- consulting experts — considering support from external advisors who will help prepare documentation, select alternative solutions appropriate to the organization’s needs (ad hoc/temporary) and enabling the effective fulfilment of statutory obligations,
- implementing contingency procedures — agreeing together with experts / the contingency solution provider how invoices will be issued and received in a situation where full KSeF integration is not available.
With such actions, the entrepreneur may demonstrate due diligence and minimize the risk of adverse consequences related to a delayed KSeF implementation.
CRIDO support
At CRIDO, we combine tax, legal and technological competencies to comprehensively support companies in the process of implementing KSeF. Our team of experts supports organizations both in planned implementations and in situations requiring rapid response on the “final stretch”.
We understand that implementing KSeF, especially in cases of unplanned changes or limited time (or other circumstances beyond the organization’s control, e.g. delays on the side of the software vendor), can be a major challenge. Therefore, we have prepared dedicated solutions aimed at providing emergency/temporary support until the organization is fully ready to implement KSeF.
As part of our support at CRIDO, we are ready, with regard to sales, to:
- help with submitting invoices to KSeF — by (i) converting raw sales data (e.g. from an Excel file) into the required XML structure and submitting it to KSeF on company’s behalf, ensuring compliance with the FA(3) scheme and all technical requirements (CRIDO team sends invoices to KSeF and provides the received metadata), or (ii) providing a web application Compass KSeF [2], in which the company can easily import sales invoice data in XML/Excel format and authorize submission, or (iii) providing an API connector enabling integration with ERP, finance/accounting, billing, workflow systems and automatic sending/receiving of invoices from KSeF,
- prepare visualizations of sales invoices from KSeF together with the required elements (QR codes) and provide them to the company,
- retrieve and provide KSeF numbers of original invoices for corrective invoices to be issued by the company,
- verify the correctness of XML files (technical and substantive tests).
With regard to purchase documents, CRIDO experts can help by:
- receiving purchase invoices in XML from KSeF and providing them to the company,
- preparing visualizations of purchase invoices and sending them to the company — after downloading invoices from counterparties submitted in XML, we will ensure a clear presentation of structured invoices for end users,
- sorting purchase invoices — if there is a need to automatically download and categorize invoices, we will help define the process based on tags and your business requirements, and agree how they are to be delivered to the indicated persons.
Details of the solutions, including specific cooperation variants, can be found in our leaflet and on the website. If you would like to discuss and receive an individual support offer — please contact CRIDO experts.
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