Poland’s new KSeF electronic invoicing system is being phased in, with Orlen providing clarification on implementation timelines and penalties.
Gradual Implementation Timeline
From February 1, 2024, taxpayers with a gross sales value exceeding 200 million złoty (including VAT) must issue invoices using the KSeF system. The requirement will extend to all other taxpayers from April 1, 2026, except for those with monthly gross sales value (including VAT) not exceeding 10,000 złoty.
These smaller taxpayers will be required to use KSeF from January 1, 2027, unless they exceed the monthly 10,000 złoty limit before then, at which point they must begin issuing invoices in KSeF from the invoice that crosses this threshold.
Penalties and Enforcement
Currently, failure to use KSeF despite the requirement will not be subject to penalties. Sanctions for non-compliance are scheduled to take effect only from January 1, 2027.



