Poland Publishes the Official List of KSeF E-Invoicing Exemptions
The Polish Ministry of Finance has formalized the specific scenarios where taxpayers are not required to issue structured invoices through the National e-Invoicing System (KSeF). This list was finalized in a new regulation signed on December 7, 2025, and published in the Journal of Laws on December 9, 2025. The regulation is scheduled to take effect on February 1, 2026, coinciding with the initial mandatory rollout of the KSeF 2.0 system for large enterprises.
Defined Categories of Exempt Transactions
The regulation identifies six primary categories where the use of structured invoices is not mandatory:
- Toll motorway services documented using reduced-data invoices under Article 106o of the VAT Act..
- Passenger transport tickets for rail, road, sea, or air travel that serve as reduced-data invoices.
- Air traffic control charges for en-route services invoiced by EUROCONTROL’s Central Route Charges Office on behalf of the Polish Air Navigation Services Agency.
- Financial and insurance services that are VAT-exempt under Article 43(1) of the VAT Act and documented with reduced-data invoices.
- Self-Billing (No Polish NIP): Transactions where the buyer in a self-billing arrangement does not have a Polish Tax Identification Number (NIP).
- Self-billed invoices in instances where the buyer does not have a Polish Tax Identification Number (NIP).
- Self-billed invoices in instances where the supplier does not have a Polish Tax Identification Number (NIP).
Taxpayers involved in any of the exempt categories listed above may still choose to issue their invoices via KSeF voluntarily. Additionally, for self-billing arrangements involving goods delivered within the EU, structured invoices can be issued through KSeF if the buyer is identified by a VAT number from another Member State.
There’s more you should know about e-invoicing in Poland – learn more about the new and upcoming regulations.
