Invoicing rules in connection with the implementation of the National e-Invoice System (KSeF)

Please be advised that KDPW S.A. and KDPW_CCP S.A. (hereinafter: KDPW Group Companies or Companies) will be required to issue and receive structured invoices in the National e-Invoice System (hereinafter: KSeF) from 1 February 2026.

KSeF is a central system of the Ministry of Finance used, among others, for issuing, receiving and storing structured invoices (hereinafter also referred to as KSeF invoices). Issuing invoices in KSeF, with exceptions set out in the Value Added Tax Act (VAT Act), will become mandatory:
 

• from 1 February 2026 for taxpayers whose sales value (including VAT) exceeded PLN 200 million in 2024,
• from 1 April 2026 for other taxpayers, except for taxpayers whose total sales value, including the amount documented by invoices issued in a given month, is less than or equal to PLN 10,000 (for them, the obligation will come into force on 1 January 2027).

Furthermore, all entrepreneurs and legal entities, regardless of size, will be required to receive invoices via KSeF from 1 February 2026 (if they use a tax identifier (NIP) in connection with the purchase of goods or services).

With reference to the foregoing, we present the most important information regarding the circulation of KSeF invoices issued and received by the KDPW Group Companies, which will apply from 1 February 2026.
 
Issuing invoices by the KDPW Group Companies
 

• KSeF will not send automatic notifications about issued invoices; each buyer required to use KSeF will download structured invoices directly from KSeF on their own.
• As a rule, the KDPW Group Companies will not inform counterparties about invoices issued in KSeF and will not make the invoice visualisation available to service buyers with their registered office or permanent place of business in Poland who participate in the purchase of goods or services for which the invoice was issued.
  
  An exception is the LEI issuance service provided in accordance with the “Rules of Registration and Maintenance of Legal Entity Identifiers by Krajowy Depozyt Papierów Wartościowych S.A.” and the data provision service provided in accordance with the “Rules of Provision of KDPW Group Reference and Statistical Data by KDPW Group for a Fee”, in which case the invoice visualisation with the assigned KSeF number will be made available to the service user in accordance with the rules currently in force.
• In cases where invoices are issued to foreign entities, the KDPW Group Companies will provide a KSeF invoice visualisation in the manner previously agreed with the buyer.
  
  We assume that the e-mail addresses provided in your declarations regarding the acceptance of electronic invoices are still valid for the purpose of providing you with invoices in the form of visualisations issued in KSeF.
  
  If you need to update the information contained in the declaration, including, in particular, a change of the e-mail address to which the invoice is to be sent, you must submit a new declaration. 
  UE1 KSeF Declaraton concerning acceptance of electronic invoices
• In the event of a general failure of KSeF, the KDPW Group Companies will send invoices in the form of electronic invoices or printouts. We assume that the e-mail addresses provided in your declarations regarding the acceptance of electronic invoices are the correct addresses for sending you electronic invoices in the event of a general failure of KSeF. 
  
  If you need to update the information contained in the declaration, including, in particular, a change of the e-mail address to which the e-invoice is to be sent, you must submit a new declaration.
  UE1 KSeF Declaraton concerning acceptance of electronic invoices
• Superior local government units (the Buyer of the service indicated in the invoice structure as Entity 2) which want the invoice to include the details of the subordinate unit acting as the Recipient, i.e. Entity 3, need to submit an appropriate declaration.
  Local government unit declaration template
• The date of issue and date of receipt of structured invoices in KSeF will be determined in accordance with the provisions of the VAT Act.

Receipt of invoices by the KDPW Group Companies
 

• From 1 February 2026, we request that you do not send visualisations of structured invoices in paper form or PDF files to the current e-mail address dedicated to sending invoices where the invoice has been issued in KSeF.
• If invoices are issued to a Company during a general failure of KSeF, please send them to the following address: kdpw@kdpw.pl.
• Attachments to invoices which are not structured attachments (i.e. they are not an integral part of the invoice and are not delivered using KSeF) should be sent to: kdpw@kdpw.pl. Please include the KSeF ID (invoice number assigned in KSeF) in the subject line of the email. This is necessary to correctly identify and link the attachment to the invoice.
• The date of issue and date of receipt of structured invoices in KSeF will be determined in accordance with the provisions of the VAT Act.