KSEF will seal the system, but is associated with challenges

A mandatory KSEF will simplify the accounting and sealing system, but will be associated with some challenges that may cause taxpayers' anxiety – says Kamil Chmielewski, tax advisor, manager in the tax consulting department at KPMG in Poland

In April 2025, the Ministry of Finance published an updated road map, on which it determined several milestones, necessary for the stage introduction of a compulsory KSEF in 2026.

Some of them, including the most important – adopting the act introducing the so -called KSEF 2.0 – has already been implemented. However, he is still waiting for, among others Launching a new KSEF 2.0 test environment.

“The basic assumptions of the KSEF from the business side are known – it is to automate the trading of invoices between all taxpayers, simplify accounting processes and seal the system. Currently, only the largest organizations mention among themselves information about the transactions made in an automatic manner, e.g. via EDI,” wrote Kamil Chmielewski in the PAP Business Commentary.

He added that thanks to KSEF, all taxpayers will have such opportunities, which should contribute to increasing the certainty of economic trading. There will be no risk that the invoice has disappeared or doubts regarding the date of its receipt, because it results directly from the Act and in principle it is equal to the date of granting the KSEF ID number.

The KPMG tax advisor points out that thanks to the introduction of mandatory KSEF, the basic VAT date from 60 to 40 days will also be shortened, which should positively affect the liquidity of many taxpayers.

“The introduction of ksef, in addition to the obvious benefits, can be associated with inconveniences in the first phase. One of the basic challenges for many entrepreneurs will be to determine what information is to be shown in individual fields of e-invoice. It may happen that different systems will provide the same information in other fields. This may lead to a situation in which the assumed automation of information exchange will not take place in the first phase of the mandatory KSEF, because information, because information They will be on the invoice, but you will still have to search for them manually ” – he wrote.

The issue of the stability of the new system also raises concern among taxpayers. In the work on KSEF 2.0, the Ministry of Finance tried to take into account these fears by introducing extraordinary modes, i.e. offline24, inaccessibility, failure and crisis situations.

“From the point of view of invoice exhibitors, it seems that they most often use offline24, which allows you to send an invoice to KSEF with a delay, i.e. on the next business day. The introduction of this mode was very positively accepted by entities participating in social consultations” – wrote Kamil Chmielewski.

“Some doubts are raised by the fact that in the case of offline24, the buyer's domestic, using the NIP number, will receive invoices, as a rule via KSEF. Therefore, the question arises what to spend the buyer at the time of sale, when the invoice itself is sent to the KSEF the next business day” – he added.

The issue of visualization of e-invoices sent to KSEF is also a separate problem. In the Ministry of Finance, work on the appropriate executive regulation (as of September 15, 2025) has not completed.

“In our opinion, the issue of visualization is extremely important, because at least in the initial period of compulsory KSEF, taxpayers will probably still be based on visualizations received in accordance with current processes,” says KPMG expert.

“Certainly a big challenge for business will be a short time between the finalization of legislation and the publication of the KSEF 2.0 test environment and the introduction of a compulsory KSEF. However, this problem seems that it was addressed by the legislator who has postponed the use of penalties for issuing invoices outside the KSEF until January 1, 2027.

It is worth emphasizing that the mandatory KSEF is therefore the next step in the digitization of the Polish economy, part of the global trend associated with the digitization of settlements between taxpayers ” – wrote Kamil Chmielewski. (PAP Biznes)

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