KSeF for carriers invoicing Polish clients: who must issue, from when

A Polish haulier invoicing a Polish client issues the invoice in KSeF, Poland's national e-invoicing system (Krajowy System e-Faktur). A Romanian or Hungarian haulier invoicing the same client usually does not. What decides it is where the seller is established, and the Ministry of Finance sets out the rules on its KSeF pages.

From February and April 2026

KSeF is mandatory for issuing invoices in Poland from 1 February 2026 for taxpayers whose 2024 sales (with VAT) exceeded PLN 200 million, and from 1 April 2026 for everyone else. Sellers with monthly invoiced sales up to PLN 10,000 gross may issue outside KSeF until the end of 2026. Receiving invoices through KSeF has been mandatory for all taxpayers since 1 February 2026.

Who has to issue in KSeF

The Ministry's KSeF pages put three groups outside the mandatory scope: taxpayers with no seat and no fixed place of business in Poland; taxpayers with a fixed establishment in Poland that does not take part in the supply the invoice documents; and sales to individuals who do not run a business. Everyone else issuing a VAT invoice in Poland must use KSeF, and a foreign taxpayer outside the obligation may still issue in it voluntarily.

For a haulier that works out as follows. A Polish carrier invoicing a Polish client is in scope, with the dates above. A Polish carrier invoicing a customer abroad is also in scope: the FAQ says invoices for intra-EU supplies, exports and services to foreign businesses are issued in KSeF, and then go to the foreign buyer in an agreed form, for instance a PDF or printout showing the KSeF number and the QR code.

A Romanian, Bulgarian or Hungarian carrier invoicing a Polish client, with no Polish establishment, is outside the obligation. For a B2B transport service the Polish buyer usually accounts for the VAT, and your invoice can be issued outside KSeF, on paper or electronically. A Polish fixed establishment that takes part in the service changes that, and the Ministry's explanatory notes ask whether the establishment is permanent enough and has the people and technical means to take part.

The same goes for a Polish forwarder (spedytor) who hires a foreign carrier. It cannot demand a KSeF invoice from that carrier as a legal duty, because the carrier is outside the obligation. It can ask for one as a commercial arrangement, and voluntary issuing is allowed. Whether that is worth the effort depends on your VAT treatment and your accountant's view.

What changes in the invoicing routine

The invoice is now a structured XML file, FA(3). The PDF is only a visualisation, and after KSeF assigns its number the seller may hand the buyer a visualisation with the KSeF number and a QR code. Issuing is online and in real time. In "offline24" mode the invoice goes to KSeF no later than the next working day, and an announced KSeF failure allows an emergency mode. For the buyer, the invoice counts as received on the date KSeF assigns the number.

Each invoice is issued under a token or a certificate, and its holder answers for what is issued with it. The deadline for issuing stays at the 15th of the following month.

Fines from 2027, unless a bill moves them to 2028

Under the law as it stands, sanctions for not issuing a structured invoice in KSeF, for issuing outside the template during a failure, or for sending an offline invoice late apply from 1 January 2027. The Ministry states that KSeF errors are not penalised between 1 February and 31 December 2026, and says it will focus on education during that year. On 20 October 2026 the government adopted a bill that moves the start of penalties to 1 January 2028 and sent it to parliament. As of 1 November 2026 it is a bill, not law. The duty to use KSeF stays either way. A Polish carrier can use the time to find problems: customer NIPs that do not match, missing buyer data, unusual VAT cases such as reverse-charge services.

KSeF filing in Druma

Druma submits invoices to KSeF for operators invoicing under a Polish VAT number, on the KSeF 2.0 interface. The environment is chosen per company (test, demo or production), and the connection uses a KSeF token or the company's own certificate. Druma builds the FA(3) document, sends each batch in one session and reads the verdict back. It stores the official confirmation (UPO), prints the KSeF number and the QR code on the invoice, and shows KSeF's own explanation on a rejected invoice. Corrective invoices and multi-order consolidated invoices are supported. For a foreign buyer the email copy waits until KSeF has accepted the invoice, so the PDF that leaves already carries its KSeF number and QR code. Druma also uses the National Bank of Poland rate for foreign-currency invoices with Polish VAT and exports the JPK_V7M records your accountant needs (finance and invoicing).

As of October 2026, KSeF filing in Druma has been validated on KSeF's test environment. No Polish operator runs it on production yet.

Before the first KSeF invoice

Decide who in the company holds the KSeF access and whether it is a token or a certificate. Compare each client's NIP and legal name with your master data. Agree with foreign clients how they get the invoice; a PDF with the KSeF number and QR code is the usual answer. Expect corrections, since a credit note becomes a corrective invoice in KSeF. And watch the failure announcements, because they change how you may deliver the invoice.