KSeF Poland Exemptions: What’s Required for FA (3) Compliance in 2026
Poland is moving to mandatory structured e-invoicing under KSeF Poland e-invoicing, with the KSeF mandatory date 2026 set for 1 February 2026. From that point, most B2B invoices must be issued as a structured invoice Poland XML FA(3) through the national KSeF system.
However, not every invoice must pass through KSeF. The Ministry of Finance has defined clear KSeF exemptions 2026 to reduce compliance pressure in specific scenarios.
Understanding where exemptions apply—and where they do not—is critical for meeting KSeF compliance requirements.
What Is KSeF and FA(3)?
For businesses still asking “fakturowanie co to?” in the KSeF context:
Under Article 106gb(8) of the Polish VAT Act, a structured invoice is an electronic invoice created using the official KSeF template. This template defines the mandatory data fields, structure, and XML format known as FA(3).
In simple terms:
Structured invoice Poland KSeF = XML FA(3) submitted via the KSeF platform
PDFs and traditional electronic invoices are no longer sufficient unless an exemption applies
This framework is the backbone of e-invoicing in Poland.
Key KSeF Exemptions for 2026
The following transaction types are exempt from mandatory submission to KSeF, even after February 2026:
Toll highway services Receipts issued with a buyer’s NIP and treated as invoices do not require KSeF submission.
Passenger transport services Tickets that are legally recognised as invoices are excluded from structured XML FA(3) reporting.
Air traffic control charges These fees may be invoiced outside KSeF under separate invoicing rules.
VAT-exempt financial and insurance services When issued as simplified invoices, these services fall outside the KSeF requirement.
Self-billing by foreign entities without a Polish NIP Invoices created by foreign taxpayers lacking a Polish NIP are exempt.
Buyer-authorised self-billing for foreign sellers Particularly in WDT (intra-EU) scenarios using a VAT-UE number instead of a Polish NIP.
These scenarios form the core of officially recognised KSeF exemptions 2026.
KSeF Authentication, APIs, and System Access
For non-exempt invoices, access to KSeF relies on defined KSeF authentication methods, including:
Qualified electronic signatures
Trusted profiles
Token-based access for systems
Developers and IT teams rely heavily on the official KSeF API documentation, which enables:
Invoice validation
Submission and retrieval
Status tracking directly from ERP systems
This is where choosing the right e-invoicing platform becomes critical.
Integration and Compliance in Practice
Achieving real compliance is not just about issuing XML files.
Businesses need:
Reliable KSeF oprogramowanie dla przedsiębiorców
Automated exemption detection
Correct routing of invoices inside or outside KSeF
Support for KSeF integracja z systemem ERP
A capable KSeF software solution Poland will integrate with systems like SAP, Oracle, or local accounting tools and follow a clear KSeF system integration guide.
Many companies rely on an experienced e-invoicing service provider in Poland to manage this complexity using certified oprogramowanie do e-faktur KSeF.
What Businesses Should Be Doing Now
Before 2026, businesses operating in Poland should:
Map transaction types Identify which invoices require structured XML FA(3) and which qualify for exemption.
Configure ERP logic Your system must intelligently decide when to send invoices to KSeF.
Document exemption usage Tax authorities may request justification for invoices issued outside KSeF.
Avoid assumptions Sending everything through KSeF is as risky as sending nothing.
This preparation is essential for long-term KSeF Poland e-invoicing compliance.
Final Perspective
KSeF is not just a format change—it’s a system change. The coexistence of structured and exempt invoices will be the norm, not the exception, after 2026.
Businesses that understand e-invoicing in Poland, implement compliant oprogramowanie do fakturowania elektronicznego KSeF Polska, and align early with the KSeF framework will avoid operational chaos when enforcement begins.
If your current setup cannot clearly separate exempt and non-exempt invoices, it’s a signal that deeper KSeF readiness work is still needed. Explore more
