The amendment to the VAT Act generates the need to settle using the National e-Invoice System. From February 1, 2026, the system will cover economic activities in the country in which the value of sales of goods and services in the previous year exceeded PLN 200 million. In accordance with the announcement of the Ministry of Finance and in connection with the modification of the legislation, from April 1, 2026, all entrepreneurs will be obliged to use settlements through the KSeF system. So what are structured invoices and who do they apply to? Find out the details!
What are structured invoices and how do they work?
The National e-Invoice System (KSeF) is an IT system within which entrepreneurs can issue and share so-called structured invoices. These documents are currently prepared in XML format, i.e. in accordance with the statutory requirements of the logical structure of the e-Invoice FA(2). It is worth adding, however, that from May 2025, the Ministry of Finance has published a new template - FA(3), which was published on the basis of:
- opinions submitted as part of tax consultations;
- demands raised during meetings with entrepreneurs, accountants and auditors.
Did you know that…? The logical structure of electronic invoices for the KSeF system must be consistent with the document template published in the Central Repository of Electronic Document Templates CRWDE.
The amendment to the VAT Act also means that from 1 February 2026 the FA(2) document versions will be replaced by the new FA(3) template.
Since when have structured invoices been in force in Poland?
The beginnings of the National e-Invoice System in Poland date back to January 2022. It was then that the Ministry of Finance decided to launch a VOLUNTARY system of structured invoices for all entrepreneurs in the country.
Only after July 1, 2024, structured electronic invoices became mandatory for entrepreneurs who are active VAT payers who issue invoices for receipts with a Tax Identification Number.
The changes introduced from 1 January 2025 with a six-month postponement generate the obligation to issue invoices using the KSeF system for:
- taxpayers benefiting from VAT exemption;
- companies issuing invoices from cash registers;
- entrepreneurs preparing simplified invoices, i.e. receipts with a Tax Identification Number up to PLN 450 - from this year, it is necessary to issue a structured invoice for such a receipt.
According to the latest changes to regulations, structured invoices are obligatory for large business entities (last year's turnover exceeding PLN 200 million), while from April 1, 2026, the National e-Invoice System will be obligatory for all companies in the country.
Who does not have to use the National e-Invoice System?
The legislation provides for several exceptions when the use of invoices through the KSeF system is not mandatory. This applies primarily to entrepreneurs who:
- they do not have a registered office or permanent place of business in Poland;
- have a permanent place of business in Poland, but this place is not directly involved in the supply of goods and provision of services.
The exemption from KSeF also applies to entrepreneurs who use special procedures under which tax settlements are carried out via OSS and IOSS procedures.
What are the benefits of using structured invoices?
Structured invoices in the KSeF system are a modern way to issue sales documents. Using this system, you save time, avoid errors in settlements and settle with the tax office more efficiently.
So why is it worth generating structured invoices? It is a beneficial solution because…
- the invoice is entered into the system immediately and cannot be lost;
- you don't have to store invoices - KSeF will do it for you for 10 years;
- the system allows you to recover VAT faster – up to 20 days earlier than standard (60 days);
- there is no need to print and send invoices by post or email;
- you can easily integrate KSeF with your own accounting program.
When you join the National e-Invoice System, you additionally gain the possibility of making easy corrections to issued invoices while maintaining the readability of settlements. Additionally, you have access to your invoices from anywhere - all you need is a stable connection to the network.
The advantage of electronic invoices in the KSeF system is also the fact that they cannot be lost or destroyed. As a user of the e-Invoices system, you are certain that the accounting document has reached the client, without having to prepare a duplicate.
KSeF what is it and how does it affect electronic invoices?
Structured electronic invoices have a unique KSeF number, which consists of a string of characters. The structure is as follows:
- Company tax identification number;
- invoice issue date in YYYMMDD format;
- the technical part of the invoice number, which consists of a generic string of 12 characters;
- checksum calculated automatically.
A structured invoice, unlike a traditional invoice, is made available in real time. This means that you can effectively automate accounting processes in this way. You will need more information about KSeF API - Documentation in this respect, it may be necessary to safely integrate the accounting system with KSeF.
Did you know that…? Structured invoices are collected in the electronic system for 10 years from the end of the year in which they were issued.
How to prepare your company for the introduction of structured invoices?
KSeF is a system based on the authentication model. This means that issuing documents in 100% is safe and there is no risk that unauthorized persons will gain access to invoices. In practice, before issuing an invoice in the system, user authentication is necessary. Authorization can be performed by Trusted Profile, Qualified Signature or Qualified Seal.
There are a few technical issues to keep in mind if you plan to use structured invoices KSeF. Token is a code that will allow you to use the full capabilities of the National e-Invoice System within the scope of: access to commercial documents, issuing invoices, viewing authorizations and managing them.
To start using the KSeF system in your company… Check if your accounting software supports KSeF and plan its update. Establish with your accounting office how the data exchange will look like and who is responsible for sending invoices. Train employees who issue or book invoices. Introduce new procedures, e.g. granting permissions to KSeF and checking sending statuses.
