Progress in respect of Poland’s envisaged Business-to-Business (B2B) e-invoicing mandate faded somewhat since the announcement of its postponement from July 2024 to February 2026. However, Poland’s Ministry of Finance has started to pick up the pace with plans for e-invoicing mandate implementation.

A consultation, scheduled for mid-July 2024, covered the following aspects:

• Postponing the liquidation of invoicing in cash registers
• Consumer invoices
• Including additional data on the invoice.

Feedback has now been provided on the July consultation.

This has yielded some proposed modifications, which include:

• The inclusion of attachments, particularly for industries which send across complex data
• An interim offline mode, which has been touted as voluntary during a potential transitional period. The offline mode covers instances where invoices are issued outside KSeF with a QR code and subsequently sent to KSeF.
• Paper invoice permissibility for small taxpayers during the transitional period.

The position of Business-to-Consumer (B2C) invoices are still under consideration.

One of the most significant proposed changes is a revised Polish Schema format. Prior to the mandate postponement, this had taken the form of the FA2. However, a revised format, draft FA3, is now expected to be published in September 2024. The FA3 will be subject to a public consultation, as is the schema for the proposed attachment. The publication of a new draft Act incorporating the key changes is expected to follow a similar timeframe.

The consultations appear to be motivated by the need to simply Poland’s previous e-invoicing infrastructure, following multiple complications identified with the KSeF platform.

Tungsten Automation had been on track to deliver a compliant e-invoicing solution in Poland in line with the original mandate commencement date of 1 July 2024. Tungsten Automation is committed to delivering a compliant solution by 1 February 2026.

We continue to follow the Polish Ministry of Finance publications for a final and definitive indication of Poland’s e-invoicing plans.