Poland's E-Invoicing Mandate: Key Updates and Compliance Requirements

Poland is preparing to implement new invoicing mandates designed to streamline business operations and enhance transparency. With these requirements set to take effect in 2026, businesses must adapt to significant changes that will reshape invoicing and compliance processes. Below we explore the latest updates and what they mean for companies operating in Poland.

Key updates to Poland’s e-invoicing mandate

After announcing a postponement of the mandate and initiating an audit of the technical solution to simplify requirements, the Polish government released a new technical specification for public review and commentary in late 2024.

The announcement also included a revision to the mandate timelines for entrepreneur businesses:

• 1 February 2026: This deadline applies to taxpayers whose turnover exceeded PLN 200 million (~EUR 46 million) in the preceding year, as well as entrepreneurs whose sales value (including tax) exceeds PLN 200 million in 2025.
• 1 April 2026: All other taxpayers must comply by this date.

Key takeaways from the published announcement

• The FA_VAT(2) structure will be updated to FA_VAT(3), but changes are mainly focused on structured attachments.
• The new specification allows attachments in a structured format (XML) to accommodate, for example, industry-specific content. However, unstructured attachments (e.g., PDF, JPEG) will not be accepted via the KSeF platform. To support unstructured data, invoice issuers can include additional information in the “Additional Description” field, such as a text-based link to an external document.
• The KSeF identifier and related dates will remain mandatory throughout the invoicing and payment processes.
• The government has announced an update to the KSeF platform in November 2025, with the FA_VAT(3) changes expected before the mandate takes effect.

What this means for companies operating in Poland

All affected businesses must ensure that the KSeF identifier is processed throughout the entire invoice lifecycle, from issuance to payment. This requires a structured approach to receiving and transmitting the identifier within your invoicing workflow.

The FA_VAT(3) structure supports key content typically required for accounts receivable (AR) and accounts payable (AP) automation. However, if your process relies on industry-specific details, you will need to use structured attachments.

For invoices that traditionally include attachments (such as PDFs), businesses need to think about the new ways of working, for example:

1. Embed a link within the invoice content, or
2. Use parallel attachment processing based on their system capabilities.

Challenges to watch for

The lack of support for unstructured attachments poses challenges for industries that commonly rely on additional documentation, such as:

• Temporary staffing agencies: Providing details of completed work.
• Repair services: Attaching work order summaries.
• Legal services: Including contracts or case details.

This raises two important questions:

1. How does the government expect these industries to handle invoice attachments?
2. If you’re a supplier or buyer in these sectors, how will you adjust your invoicing and invoice handling processes to comply?

Act now to ensure compliance

Although the specifications are not yet final, we anticipate only minor changes. We strongly recommend that businesses begin preparations now by selecting a service provider and taking steps toward compliance with Poland’s mandate.

How Basware can help

Basware provides comprehensive support to help businesses navigate Poland’s evolving invoicing requirements. Contact us to learn how we can assist in ensuring compliance.

If you’re just getting started, download our Buyer’s Guide to Invoice Compliance Solutions to explore key considerations, critical questions, and proven strategies for selecting the right solution provider.