kto-zaplacil.pl

Legal position as at 9 November 2026. All linked sources are in Polish.

KSeF's PLN 10,000 limit ends on 31 December 2026

The PLN 10,000 limit lasts only until 31 December 2026. From 1 January 2027, you issue invoices to businesses in KSeF regardless of the amount or your sales. The exception for invoices from cash registers and for receipts showing the buyer's NIP of up to PLN 450 ends at the same time, so an invoice for a cash register sale to a business also has to be issued in KSeF.

KSeF (Krajowy System e-Faktur) is Poland's National e-Invoicing System. The limit lets a business issue invoices outside it, on paper or as PDFs, while its invoiced sales stay within PLN 10,000 gross a month. NIP is the Polish tax identification number, and a cash register here means a kasa rejestrująca, the fiscal device that prints receipts.

Both exceptions are transitional provisions: Art. 145m of the VAT Act applies from 1 April to 31 December 2026, and Art. 145n from 1 February to 31 December 2026. The Act puts no new threshold in their place. On invoices for receipts, the Ministry of Finance writes: “Po tym okresie wszystkie faktury będą wystawiane przy użyciu KSeF” (after this period, all invoices will be issued using KSeF).

The Sejm (the lower house of Poland's parliament) has not extended these exceptions. The act that moves the KSeF penalties, passed by the Sejm on 6 November 2026, does not change Art. 145m or Art. 145n, and MPs rejected an amendment that would have given microbusinesses until the end of 2027 (168 for, 235 against, 40 abstentions). The Senate has still to consider the act.

Does the sale date or the invoice date decide?

The issue date decides. Art. 145m refers to invoices “wystawionych w danym miesiącu” (issued in a given month), and the Ministry of Finance assigns an invoice to the limit by its issue date, even if the sale took place earlier. An invoice issued in 2027 for a December 2026 sale must therefore be issued in KSeF.

You can use the limit until the end of 2026 only if no earlier invoice has exceeded it. The invoice that took you over PLN 10,000 in a month and every invoice after it must go into KSeF, even in months with lower sales (Art. 145m ust. 2). The limit counts the gross amounts of invoices that would otherwise have to go into KSeF.

Marek, a programmer, finished a contract on 29 December 2026 and is owed PLN 6,150 gross. Marek has issued no other invoices in December and has never exceeded the limit. An invoice issued on 30 December can still be a PDF. One issued on 4 January 2027 must be issued in KSeF.

What changes at the cash register?

Until the end of 2026 you can issue an invoice at the cash register outside KSeF, and a receipt showing the buyer's NIP for up to PLN 450 (EUR 100) counts as a simplified invoice and also stays out of the system (Art. 145n ust. 1). From 1 January 2027, Art. 111 ust. 3a pkt 1 requires a fiscal receipt (paragon fiskalny) for every sale, and the words “lub fakturę” (or an invoice) disappear from the provision. In the explanatory memorandum to the bill, the government confirms that from that date “nie będzie możliwe już wystawianie faktur z kas rejestrujących” (it will no longer be possible to issue invoices from cash registers).

If you sell to a business and issue an invoice for a cash register transaction, from 2027 you do so in KSeF. The condition stays the same: you can issue an invoice to a taxpayer for a sale documented by a receipt only if the receipt shows their NIP (Art. 106b ust. 5).

If you break that rule, the tax authority sets an additional tax liability equal to 100% of the VAT on the invoice (Art. 106b ust. 6). It does not set one for individuals who are liable for a petty fiscal offence or a fiscal offence for the same act. Ust. 5 and 6 do not apply to taxi services, other than the hire of passenger cars with a driver (Art. 106b ust. 7).

The relief in Art. 145n ust. 3 covers the invoices and receipts in ust. 1, meaning those issued from 1 February to 31 December 2026. If, from 1 January 2027, you issue an invoice for a sale recorded on a cash register, you keep in your records, along with the invoice data, either the document number and the cash register's unique number from the receipt, or the paper receipt itself (Art. 106h ust. 1). This is our own reading of the rules: we found no Ministry of Finance position on it.

Halina runs a hardware shop. In December 2026 a business buys drill bits for PLN 246 and gives its NIP at the till, so the receipt with the NIP is a simplified invoice. None of the sources we read says outright what such a receipt will be from January 2027. In our view it is an ordinary receipt, and if the business wants an invoice, Halina issues it in KSeF.

Who can still invoice outside KSeF?

Art. 106ga ust. 2 excludes, among others, invoices to individuals not running a business and invoices from taxpayers with no registered office or fixed establishment in Poland. The Ministry of Finance's list of exclusions also includes, for example, toll motorway journeys and single-journey transport tickets. You can issue an invoice to a consumer in KSeF voluntarily (Art. 106ga ust. 4).

Being VAT-exempt under Art. 113 does not take you out of KSeF. Art. 106ga ust. 2 pkt 6 covers only the SME scheme in Art. 113a, so if you invoice businesses as a VAT-exempt taxpayer, you also use KSeF from January.

What about invoices issued outside KSeF in 2026?

We found no provision or Ministry of Finance position requiring you to enter them into KSeF after 1 January 2027. They have no KSeF number, so the payer cannot quote one in the transfer, even when paying in 2027.

In our view, you issue a 2027 correction to such an invoice in KSeF. Art. 106j ust. 2 pkt 2a waives the requirement to give the KSeF number of an original invoice that never received one, and the FA(3) invoice structure has a field for such corrections, NrKSeFN. The Ministry of Finance confirms that a 2025 invoice can be corrected in KSeF. We found no Ministry position, however, on whether such a correction has to be issued in KSeF.

What should you do before January?

If you currently issue invoices on paper or as PDFs, set up KSeF access by the end of December. The KSeF Taxpayer Application (Aplikacja Podatnika KSeF) is free. From January your invoices will get KSeF numbers. If you are an active VAT payer (a VAT-registered business that is not exempt), payers that are also active VAT payers are to quote them in transfers, so after the first payments check your statement with the kto-zaplacil.pl tool.

Sources

This article is for information only and is not tax advice.