# KSeF in Poland from January 2027: penalties delayed, payments change > For finance and operations leads at European companies with a Polish entity or Polish suppliers. What changes in January, what is only a draft, and what to check now. - **Canonical URL:** https://appwave.dev/en/blog/ksef-poland-2027-penalties-delayed-ksef-number-payments - **Language:** en - **Updated:** 2026-11-13 --- - **Published:** 2026-11-13 - **Author:** Mateusz Cieśliński - Co-Founder, DevOps Engineer - **LinkedIn:** https://www.linkedin.com/in/mateusz-cie%C5%9Bli%C5%84ski/ - **Reading time (min):** 7 - **Topics:** KSeF, Automation, E-invoicing ![A pile of invoices and receipts flows into one drawer, then to a bank transfer with an outlined field for the KSeF number](https://cms.appwave.dev/uploads/ksef_poland_2027_penalties_delayed_ksef_number_payments_113532deaf.webp) **As of 4 November 2026: from 1 January 2027 Poland's KSeF e-invoicing system covers every business, while the government wants to delay monetary penalties for KSeF errors until 1 January 2028. That delay is still a draft in parliament. For companies already issuing e-invoices, the bigger January change is on the paying side: KSeF numbers in bank transfers.** Most English guides to KSeF still describe the 2026 roll-out. If you run finance for a Polish subsidiary, or your shared service centre pays Polish suppliers, January brings a different set of tasks. They touch your bank, your accounting system and the people who approve purchases. ## What changes in KSeF on 1 January 2027 From 1 January 2027 the last exemption ends. Until the end of 2026, Polish businesses whose monthly invoiced sales do not exceed PLN 10,000 gross can still issue paper or PDF invoices. After that, every domestic B2B invoice goes through KSeF, the National e-Invoicing System (Krajowy System e-Faktur). The table looks at the changes from the side of a company that buys and pays. Issuing invoices is just part of the picture. - **End of the PLN 10,000 exemption for invoices outside KSeF.** From: 1 January 2027. Legal status: in force in the VAT Act. Who it affects in your company: purchasing, small suppliers. What to check: which suppliers still send PDFs. - **Till receipts with the buyer's tax number (NIP) stop being simplified invoices; cash registers stop issuing invoices.** From: 1 January 2027. Legal status: in force in the VAT Act. Who it affects in your company: staff with company cards, fuel, travel. What to check: ask for a KSeF invoice instead. - **KSeF number or collective identifier in transfers.** From: payments made from 1 January 2027. Legal status: in force (Article 108g). Who it affects in your company: accounts payable, banking, ERP. What to check: whether payment files carry the number. - **Monetary penalties for invoices outside KSeF.** From: planned for 1 January 2028. Legal status: government draft of 20 October 2026. Who it affects in your company: management. What to check: do not plan around the delay. Invoices to consumers can still be issued outside KSeF. That does not change. ## Are KSeF penalties delayed until 2028? Yes, but only in a draft so far. **The obligation to use KSeF from 1 January 2027 is not postponed.** On 20 October 2026 the Council of Ministers adopted a draft amendment to the VAT Act that extends the penalty-free period for KSeF errors to 31 December 2027. The Ministry of Finance wrote plainly that this "does not mean giving up the obligation to use KSeF". The amendment is meant to take effect on 31 December 2026. It still has to pass the Sejm and the Senate and be signed by the President. Until then, the law says penalties start on 1 January 2027. Under Article 106ni of the VAT Act they can reach 100% of the VAT on an invoice issued outside KSeF, or 18.7% of the total amount where no VAT is shown. During 2027 the tax administration says it will focus on supporting taxpayers. It will still respond to invoices issued outside the system and check whether skipping KSeF leads to unreliable VAT returns. KPMG Poland also notes that the delay does not cover fiscal criminal provisions. In short, the delay protects you from a fine for an honest mistake. It does not protect a company that ignores the system. ## The KSeF number in payments: what your finance team must change This is the change that is easiest to miss. For payments made from 1 January 2027, an active Polish VAT taxpayer paying another active VAT taxpayer for a KSeF invoice must quote that invoice's KSeF number in the payment reference. The payment date counts, not the invoice date. According to the Polish commentaries on Article 108g of the VAT Act that we reviewed: - the rule covers ordinary transfers and split payment transfers, - when one transfer pays several invoices from the same supplier, you can quote a collective identifier instead of listing every number, - cash payments and offsetting are not covered, because they have no payment reference, - the rule does not reach invoices issued outside KSeF in 2026, because they have no KSeF number. The Act sets no separate fine for a missing number. The problem is practical. A KSeF number has 35 characters, and nobody types that by hand for fifty payments on a Friday afternoon. If your payments come from an ERP or a bank file, the number has to flow there automatically from the invoice downloaded from KSeF. Ask your software provider about it this month. In the projects we run, integrations always go first in the schedule because they are what slips, not the screens. We explained why in [why integrations go first in the schedule](https://appwave.dev/en/blog/why-integrations-go-first-in-the-schedule). ![Diagram: KSeF invoice, KSeF number, transfer with number, payment matched; several invoices use a collective identifier](https://cms.appwave.dev/uploads/ksef_poland_2027_penalties_delayed_ksef_number_payments_diagram_be6c16b436.webp) ## Does this apply to foreign companies? It depends on where the company is established. The Polish Ministry of Finance says a business without its seat or a fixed establishment in Poland does not have to issue invoices in KSeF. The duty to receive invoices through KSeF does not apply to foreign entities either. A Polish subsidiary is different. It is a Polish taxpayer, so everything in this article applies to it, including the payment rule. If your group pays Polish suppliers centrally from another country, ask your Polish adviser whether the paying entity counts as an active Polish VAT taxpayer. That decides whether Article 108g applies to those payments. ## What we see in the market: AI assistants skip the payment rule On 4 November 2026 we asked four AI assistants with web search what changes in KSeF on 1 January 2027 for a company already issuing e-invoices. All four described the penalty delay correctly. They differed on payments. ChatGPT (asked in English) and Perplexity (asked in Polish) did not mention the KSeF number in transfers. ChatGPT concluded that such a company can "generally carry on as before". Claude described the payment rule but tied it to direct debits, which narrows it. Gemini described it correctly. If your finance team asks an assistant instead of an adviser, the answer may miss the change they will feel most in daily work. ## What this means for your company **Probable conclusion:** for a company of 10-200 people, the biggest January change is in payments, not invoicing. Issuing e-invoices has been routine since April 2026. Quoting KSeF numbers in transfers adds a new step that touches your bank, your accounting system and your people. **Probable conclusion:** from January, automating purchase invoice handling gets simpler. When nearly all domestic B2B invoices arrive in one structured format, it is easier to code them, route them for approval and match them to payments. The exceptions remain foreign suppliers and purchases from private individuals. **Hypothesis to test:** the penalty delay will slow some small suppliers down. In January you may still receive PDFs or till receipts from them. Agree in advance what your accounts team does when that happens. If you are considering automation, start with one task, such as coding purchase invoices. Our article on [accounting automation in an accounting firm](https://appwave.dev/en/blog/accounting-automation-in-an-accounting-firm-where-it-actually-saves-time) shows where it saves time. Not every step needs AI. A simple script is often enough, as we explain in [script or agent: one process, two bills](https://appwave.dev/en/blog/ai-automation-in-the-workplace-script-or-agent-one-process-two-bills). ## What to do this week Five steps that take a few hours now and save a stressful January: 1. Ask your accounting or ERP provider whether transfers sent from the system will carry the KSeF number and the collective identifier from 1 January. Get the delivery date in writing. 2. Check how your Polish entity pays suppliers: manually in online banking, by bank file or from the ERP. Manual transfers with a 35-character number invite mistakes. 3. List the Polish suppliers who sent PDF or paper invoices in October. They join KSeF in January. Let them know you expect KSeF invoices. 4. Update the guidance for staff with company cards in Poland: from January, ask for a KSeF invoice, not a till receipt with the company's tax number. 5. Decide with your accounts team whether purchase invoices should get a project code and an approver automatically. If yes, you can work through it with a team that [builds this kind of automation](https://appwave.dev/en/services/ai-automation) and leaves you documentation your accountant can read, not just a developer. We are not tax advisers, and the draft delaying penalties may still change in parliament. Confirm the details with your Polish accountant before you decide. ## Sources - Ministry of Finance (Poland), "Rada Ministrów za odroczeniem kar za błędy w KSeF i przedłużeniem odwrotnego obciążenia VAT", 20 October 2026, [gov.pl](https://www.gov.pl/web/finanse/rada-ministrow-za-odroczeniem-kar-za-bledy-w-ksef-i-przedluzeniem-odwrotnego-obciazenia-vat) (accessed 4 November 2026) - Ministry of Finance (Poland), "Zasady obowiązywania KSeF i przepisy prawne", [ksef.podatki.gov.pl](https://ksef.podatki.gov.pl/ksef-news/zasady-obowiazywania-ksef-i-przepisy-prawne/) (accessed 4 November 2026) - KPMG Poland, "Extension of the deferral of penalties for errors in using KSeF until the end of 2027", 17 September 2026, [kpmg.com](https://kpmg.com/pl/en/insights/taxes/tax-alert-extension-of-the-deferral-of-penalties-for-errors-in-using-ksef-until-the-end-of-2027.html) (accessed 4 November 2026) - AppWave test of four AI assistants (ChatGPT, Perplexity, Claude, Gemini), 4 November 2026 ## Questions & Answers (FAQ) ### Has KSeF in Poland been postponed to 2028? No. Only the monetary penalties are set to move. On 20 October 2026 Poland's Council of Ministers adopted a draft under which penalties for KSeF errors would apply from 1 January 2028. The draft is now in parliament. The obligation to issue invoices through KSeF still covers every business from 1 January 2027, and the tax administration says it will respond to invoices issued outside the system. ### What changes on 1 January 2027 for a company that already uses KSeF? Issuing invoices stays the same. Three things around it change: payments to another active VAT taxpayer must quote the invoice's KSeF number or a collective identifier, till receipts showing the buyer's tax number stop counting as simplified invoices, and the smallest suppliers lose the right to send paper or PDF invoices. Most of the work therefore sits in purchasing and accounts payable. ### Is there a fine for leaving the KSeF number out of a bank transfer? According to the Polish commentaries on the rule that we reviewed, the VAT Act sets no separate penalty for omitting the KSeF number. The consequences are practical: the supplier may fail to match the payment to the invoice, and the tax office may find it harder to link the two. If a payment should have gone through split payment but did not, the split payment sanctions apply. ### Does a foreign company have to use KSeF from 2027? According to Poland's Ministry of Finance, a business without its seat or a fixed establishment in Poland does not have to issue invoices in KSeF, and the duty to receive invoices through KSeF does not apply to foreign entities or consumers. A Polish subsidiary of a foreign group is a Polish taxpayer, so it follows the same rules as any other Polish company. ### Do KSeF penalties apply in 2027 if the draft is not passed in time? If the amendment is not enacted before 1 January 2027, the current law applies, and it says monetary penalties start on that date. The government wants the change in force on 31 December 2026, but it still needs approval from both chambers of parliament and the President's signature. Plan your preparation as if penalties could start in January. --- ## About AppWave AI development company from Łódź, Poland. We build custom AI software, automation agents and web applications. We co-create them with the client and guarantee every system we deliver. - **Legal name:** AppWave sp. z o.o. - **Address:** ul. Kolumny 147E/1, 93-611 Łódź, Poland - **Phone:** +48 538 441 413 - **Email:** office@appwave.dev - **Business hours:** Monday-Friday, 09:00-17:00 - [Book a Free Consultation](https://appwave.dev/en/appointment)