KSeF penalties from 1 January 2027: invoice records your accountancy firm should keep
The Ministry of Finance has confirmed that administrative fines for the National e-Invoicing System start on 1 January 2027 and may reach 100% of the VAT on an invoice. Your accountancy firm needs a record of the KSeF number, offline24 status and permissions before the head of the tax office asks for a named document.
On 23 August 2026 Infor reported the Ministry of Finance’s reply to a parliamentary question on fines in the National e-Invoicing System: KSeF 2027. MF odpowiada na obawy przedsiębiorców dotyczące wysokich kar. The text of interpellation no. 17163 is in the Sejm system: Interpelacja nr 17163. MP Włodzisław Giziński tabled it on 14 May 2026. Zbigniew Stawicki, under-secretary of state and deputy head of the National Revenue Administration, signed the reply on the minister’s authority.
The employers’ associations cited by the MP want the level and design of the sanctions looked at again before administrative fines take effect on 1 January 2027. The VAT Act cap is up to 100% of the VAT shown on the invoice, or up to 18.7% of the total amount where the invoice shows no VAT. The ministry says protective mechanisms, scaling of fines and the power to refrain from imposing a penalty are already in the law. The period without administrative fines is meant for education and implementation.
If your firm issues or collects invoices for dozens of clients, this exchange is not a newspaper column. From April 2026 the duty to issue through KSeF already covers most taxpayers. Until the year-end a relief remains for sales documented by invoices of up to PLN 10,000 gross a month, and article 106ni fines stay suspended. After that the head of the tax office may impose a penalty by decision. KSeF invoice records should then show whether the document went into the system, in which mode, under which number, and whether someone in your firm had permission to send it.
GESOFT — Paweł Matusiak, Laravel, Vue, Android — does not replace KSeF, the Taxpayer Application or your finance and accounting package. We build a panel beside what you already use: the document list, session status, permissions, the client contract, the e-Delivery mailbox. If a SaaS integrator is enough, we will say so. If you have your own workflow and a boxed product does not cover it, we send a quote within 24 hours via kontakt. To start we need: how many VAT numbers you handle, who issues invoices today, which accounting package you run, and whether you hold KSeF 2.0 certificates.
Interpellation no. 17163 and the Ministry of Finance reply
The MP writes that Poland’s e-invoicing preparation ran for about five years, during which the timetable shifted and technical problems appeared. A shortened implementation window raised uncertainty and cost. Compared with other EU countries, Polish employers regard the model as markedly more restrictive. Some breaches at the start may come from technical or organisational errors rather than from a taxpayer acting on purpose.
He puts three questions to the minister. Whether the ministry is considering lower maximum thresholds and genuine scaling of fines. Whether a taxpayer will be protected when a breach stems from causes beyond their control, including system problems. Whether, in the first period, education and support should take priority over repression. Infor summarised the reply on 23 August. The ministry does not announce a cut in the caps. Its wording: sanctions were introduced first of all to ensure the system works effectively and universally. The primary aim is timely issue and transmission of invoices in KSeF. The second is to tighten VAT and limit abuse.
What the reply does not contain is worth recording as well. There is no promise to cut 100% or 18.7%. There is no new, separate “education period” after 1 January 2027. The ministry says education and support are already running in 2026 because administrative fines are deferred. Article 106ni is also to exclude fiscal-criminal liability in 2026 for incorrect use of KSeF. We do not carry that exclusion forward into 2027 — the communication does not.
For the owner of a practice with 40 companies on contract and 80 sole traders, the date is concrete. Until December 2026 you can still patch permissions, test offline24 and wire the client portal to the API session. From January the fine lands on the taxpayer, but the client will phone you, because you were supposed to “handle KSeF”. If the panel does not show who clicked Send, at what time and with which certificate, you are left with an email and a screenshot from the Taxpayer Application. The head of the tax office will not treat that as a register.
Article 106ni of the VAT Act and the timetable of the duty
The fines in the ministry reply are those in article 106ni of the VAT Act of 11 March 2004 (Journal of Laws of 2025, item 775, as amended). They apply from 1 January 2027. The ministry’s wording: thanks to the deferral of sanctions, taxpayers will have more time to adapt to the new rules without fear of adverse consequences. Until the end of 2026 the revenue administration is to focus on education.
The duty to issue does not wait until 2027. The Ministry of Finance KSeF portal sets the dates on Zakres obowiązkowego KSeF. From 1 February 2026 those taxpayers issue whose sales including tax exceeded PLN 200 million in 2024. From 1 April 2026 — everyone else, unless the value of sales documented by invoices for monthly periods does not exceed PLN 10,000 gross. Those taxpayers have no duty to issue in KSeF until the end of 2026. Receiving invoices through KSeF has been mandatory from 1 February 2026 for everyone covered by the system.
The roadmap at Etapy wdrożenia KSeF 2.0 adds what happens on 1 January 2027: the duty for previously exempt businesses under the PLN 10,000 monthly cap. That day also ends the period in which the legislature deliberately held back article 106ni fines. The issuing timetable and the penalty timetable are two separate clocks. In a practice they are easy to mix up when a client says “KSeF has been running since April”. It has. The fine for a missing structured invoice has not.
Exclusions from the duty to issue sit on the same MF page. Among those who do not issue in KSeF are taxpayers with no seat or fixed establishment in Poland, invoices to a natural person not carrying on a business, the non-Union OSS procedure, IOSS, occasional international passenger transport, and supplies under the article 113a SME exemption. Until the end of 2026 episodic rules also remain: electronic or paper invoices where monthly sales documented that way are no more than PLN 10,000 gross, and invoices from cash registers plus receipts with the buyer’s NIP treated as simplified invoices (up to PLN 450 or EUR 100). Your practice software cannot “guess” these exceptions. They have to hang on the client’s VAT number as a rule someone set on purpose.
The article 106ni cap is an “up to” figure. In the interpellation and in Infor’s report those rates are the source of unease, because an invoice with PLN 23,000 of VAT has a maximum fine of PLN 23,000, and an invoice with no VAT for PLN 50,000 faces up to 18.7% of the total amount. The ministry repeats that the amount in a given case will be scaled. It does not give a percentage formula or a minimum. The Act does not require the head of the tax office to take one hundred per cent every time.
In the office that abstraction turns into three numbers on the document card. Net, VAT, gross. The KSeF number or a clear absence of one. Mode: online, offline24, outage. If a client asks “what do we face for this one invoice that is not in the system”, the bookkeeper should open the card and say: VAT on the document is X, so the article 106ni ceiling is X — not “some KSeF fine”. Without those fields the conversation slides into guesswork. Guesswork is still cheap in August 2026. In January 2027 it is not.
The head of the tax office imposes the fine by decision. Not a PIP on-the-spot ticket, and not an API automaton. Before the decision goes out, someone from the office will ask for the document. If you run accountancy practice software with a client portal, that document should be findable by NIP, sales date, your own number and the KSeF number. Searching the mailbox of a bookkeeper who happens to be on leave is not a procedure.
A typical client list mixes KRS companies, CEIDG sole traders and VAT-exempt entities. The 18.7% cap applies to invoices with no VAT shown. If you issue those documents for exempt clients, the register must keep the rate and the exemption base next to the gross amount. Otherwise someone will, a year later, multiply 18.7% by the wrong line. The Taxpayer Application will not fix that, because it holds the invoice, not your note “client on exemption, receipt up to PLN 450, outside KSeF until December”.
Scaling the fine under article 189d of the Code of Administrative Procedure
The ministry points to Title IVA of the Code of Administrative Procedure (Journal of Laws of 2025, item 1691). Where the VAT Act is silent, those rules apply to the imposition of a financial penalty. When setting the amount the authority is to take into account, among other things, article 189d of the Code. Infor lists the catalogue: the weight and circumstances of the breach, how often the duty was missed in the past, previous punishment for the same conduct, the party’s contribution, steps taken voluntarily to avoid the effects of the breach, the amount of any benefit obtained, and, for a natural person, personal circumstances.
That catalogue is useful only if you have something to fill it with. “Frequency” needs a history: how many invoices for this NIP went outside KSeF, how many came back with an FA(3) schema error, how many sat in offline24 longer than a day. “Voluntary steps” is not the owner’s rubber-stamped statement. It is a timestamp of a resend, a correction, an outage report, an email to the API integrator with a session number. If the panel does not store that, in 2027 you will be writing explanations from memory.
The party’s degree of contribution is especially awkward in a practice. The client says they gave you the login. You say they were supposed to issue the invoice themselves in their sales software. The contract is silent. The head of the tax office does not settle a civil dispute between the practice and the company. The fine goes on the taxpayer. Then the taxpayer arrives with the decision. KSeF invoice records will not replace the contract, but they will show whether on day X the permission to issue sat with the practice or only on the client’s profile.
Personal circumstances apply to a natural person. In practice, a sole trader whose invoices you issue. Do not type “difficult situation” without a document. Record: sickness confirmed by a medical certificate, a line fault reported to the operator, a ticket with the API integrator. The authority will still judge the case itself. Your job is smaller: do not lose the papers the client brings when the decision is already on its way.
Separately the ministry stresses force majeure: where the breach occurred because of it, the tax authority will be able to refrain from imposing a penalty. “Will be able to” — not “shall refrain”. Force majeure is not the integrator’s Friday off and not a bookkeeper’s full disk. It is an event the party could not foresee or prevent while taking ordinary care. The burden of making it plausible sits with the taxpayer.
Day-to-day work more often produces something weaker than force majeure: an API timeout, a “session expired” message, a certificate that died overnight, no internet in the high-street office. For that the ministry points to offline24, not the force majeure clause. Mixing the two paths in an email to the client is a mistake. Offline24 is a statutory procedure under article 106nda. Force majeure is a ground for dropping a fine when the emergency mode was not enough or the event sat outside KSeF.
If your server room really goes down, or the county is without power for twelve hours, the register should collect: start and end time, the operator’s or host’s notice, the list of invoices that were due in that window, and what you did once the link returned. A single PDF named “outage.pdf” dropped into the client folder three weeks later carries no weight. A note on the document card with a time is weaker than a notarial deed, but it exists. The head of the tax office does not require a notarial deed anyway.
Offline24 mode when you cannot reach the system
On protecting the taxpayer where the cause is beyond their control, the ministry points to offline24. You may use it, among other cases, when network quality or a lack of internet makes it hard to issue and send e-invoices. It is also meant to answer worries about long processing times in KSeF. The procedure is set by article 106nda of the VAT Act.
In the panel this mode cannot be a hidden “send later” checkbox that someone ticks for convenience. The bookkeeper should see the reason: no connection, a timeout, an unavailability message, an operator decision that there is an outage. For every such document: the time of issue outside the system, the time of the send attempt, the time the KSeF number was assigned, a QR code if the document went to the buyer before the number arrived. A client who issues an invoice from a building site on a phone at 16:40 on a Friday will not wait for your office on Monday if offline mode is not in their sales app.
A practice that issues invoices for the client has a different problem. Field staff drop a photo of a delivery note into a messenger. The bookkeeper types it up and sends. If KSeF does not answer, the document sits as a draft. A draft is not an invoice. Offline24 is an invoice issued outside the system that you still have to transmit. The difference is legal, not cosmetic. On the document list the statuses draft, offline24, sent, rejected by schema, number assigned must be separate states. One green tick three days later says nothing about Friday.
Until the end of 2026 a delay in transmission is not punished under article 106ni. That sentence belongs to the transitional period, not to a promise for 2027. If you build a habit of “we will send it next week, there are no fines anyway”, you will have a queue in December. A queue on 2 January will not qualify as force majeure. It will go to the head of the tax office.
Who bears the liability: the taxpayer or the practice
The person responsible for issuing invoices is the taxpayer. The practice — where the contract says so. The finance ministry has repeated that split around KSeF many times; the KSeF 2.0 handbook sets out the variants of co-operation. Variant one: the client issues in software wired to the API, the practice only books. Variant two: the client grants the practice access to invoices, the practice pulls sales and purchases and does not issue. Variant three: the practice issues in KSeF under a permission granted by the taxpayer.
In your client contract those three variants often sit in one paragraph headed “bookkeeping and invoices”. That is not enough. From 2027 the fine goes on the taxpayer’s NIP. If you issued without written authority, a dispute about reclaiming the fine will be civil and long. If the authority is there and the panel does not log who in the practice used the certificate, the dispute will be about whether you took proper care. A log with the bookkeeper’s name, the certificate number and the time is cheaper than an expert opinion.
Permissions in KSeF 2.0 are granted in the system, not in an email. The taxpayer, a person or entity named by the taxpayer (including an accountancy firm), persons listed on a ZAW-FA notice — the catalogue is on the MF page on the scope of the duty. KRS businesses appoint an e-Delivery mailbox administrator separately; that is another service, another address, another login. Mixing the e-Delivery account with the KSeF certificate into one “access for the practice” ends with nobody knowing what to collect after a member of staff leaves.
A practical checklist for a new client is short and does not replace the contract. Who issues sales invoices. Who pulls purchases. Whether the practice has permission to issue or only to read. Which certificate, valid until when. Whether the client has their own sales software wired to the API. Whether B2C invoices and receipts go outside KSeF. Who collects e-Deliveries. Those seven answers should sit on the NIP card before you take the first period. We set this out more broadly in KSeF 2026 in a company application — here we add the practice layer: many VAT numbers, one team, one certificate or twenty.
Fields the head of the tax office will ask about on a document
When a request arrives, nobody asks for a “nice dashboard”. They ask for the invoice. On the document card you need fields you can export to PDF or CSV without improvising. The list below is a list of fields, not decoration for the chapter.
- Seller NIP and buyer NIP, name, your own invoice number
- sales date, issue date given by the taxpayer, date sent to KSeF
- mode: online, offline24, outage / unavailability
- KSeF number once assigned, or a clear absence of a number
- status: draft, sent, rejected (FA(3) schema error code), accepted
- net, VAT, gross; rate; a flag if the invoice shows no VAT
- API session identifier or the Taxpayer Application message
- who approved the send: a practice user or a client user
- certificate or token used on send and its expiry date
- attachment: whether the e-Tax Office function was notified, whether the attachment went with the invoice
- correction: number of the corrected document and its KSeF number
- whether the document is excluded from KSeF (B2C, OSS, SME, cash register, PLN 10,000 cap) and on what legal basis
Issue date and send date are two different stamps. The ministry has explained in earlier interpellation replies, among other places, that the tax point does not turn on the “send” click but on the supply. For an article 106ni fine, though, it matters whether a structured invoice came into being on time and whether it was transmitted after offline use. A panel that keeps a single “document date” will cost you an argument in 2027.
The FA(3) schema error code deserves its own field, not a comment. Integrators return validation numbers. The bookkeeper does not need XSD off by heart. They need to know the invoice came back because the buyer’s NIP is missing or the rate is wrong, and who is to fix it: the client in the sales program or the practice. If an error sits for three days as “to be clarified”, in January 2027 three days may be the difference between a late send and a fine.
An invoice attachment has been a voluntary function from 1 February 2026, after a notification in the e-Tax Office. The ministry designed it mainly for utilities, telecoms and fuel, where measures and quantities do not fit on the face of the invoice. In a practice that serves an energy company or a gas supplier, the lack of a “attachment notified / not notified” flag ends with someone sending FA(3) alone, and the counterparty ringing for the specification. The attachment is part of the invoice. Marketing copy must not go in it — that is what the scope page says.
Permissions, certificates and tokens in KSeF 2.0
Authentication in KSeF: Trusted Profile, qualified signature, qualified seal — the methods are in the implementing rules and on podatki.gov.pl. A practice that logs in as the company owner “because it is easier” breaks the permission model. After an inspection or after a member of staff leaves, you cannot revoke what you never granted. You grant permission to the entity (the practice) and to named people in the practice. You revoke it on the day the contract ends or the bookkeeper leaves.
Tokens and certificates may coexist until the end of 2026. From 1 January 2027 certificates remain the target. We are not inventing that for this article — that is how integrators and the KSeF 2.0 materials describe the timetable. In the practice panel every NIP should have: authentication type, issue date, expiry date, who applied, serial number or identifier, alerts 30 and 7 days before expiry. A certificate that dies in the night from 31 December to 1 January is a worse joke than a missing invoice.
ZAW-FA remains for basic permissions when the system will not take an electronic application. In January 2026, during the KSeF 1.0 technical break, the ministry itself pointed to the form. In 2027 do not plan ZAW-FA as a daily path. Plan it as a fallback. In the permissions register: date filed, date confirmed, a scan or official acknowledgement, whom it covers. An empty “we will do it later” row on a new client means that for two weeks nobody can lawfully issue that client’s invoices from your office.
Access to purchases is a separate permission. From 1 February 2026 receiving invoices through KSeF is mandatory. A practice that books purchases from a PDF email “because that is how the client sends them” has, since April 2026, been working from a copy, not from the document in the system. The copy may match. It may also be old. Pulling the KSeF purchase list once a day and comparing it with what the client dropped in a folder is dull. It is also the only way not to book an invoice that is not in KSeF, or to skip one that is.
Client portal, KSeF and e-Delivery in one workflow
A structured invoice does not finish the practice’s work. Beside KSeF sits the e-Delivery mailbox. Dates are on biznes.gov.pl — e-Doręczenia dla przedsiębiorców and on the MRiT page. CEIDG firms registered by 31 December 2024 must have an e-Delivery address from 1 October 2026. KRS entities from before 2025 — from 1 April 2025. Professions of public trust, including tax advisers, from 1 January 2025. If after 30 June 2025 a CEIDG client updated their entry, they already needed the address when filing the application.
An article 106ni penalty decision will arrive in the mailbox, not by fax. A practice that “watches the client’s email” will miss the appeal deadline. In the client portal you do not need a second e-Delivery mailbox — you must not replace that — only a status: whether the NIP has an electronic delivery address, who administers the mailbox, whether correspondence from the tax office and KAS should land in the practice’s messages under a power of attorney. A UPL-1 power of attorney is not a login to the mailbox. The holder of the address issues the login.
Three systems, three logins, one person in the office holding them together. KSeF — invoices. e-Delivery — official letters. The accounting package — the books. A panel that shows, against the NIP: last invoice (KSeF number, status), last letter from the office (date of delivery), whether the SAF-T for the period went out, saves half an hour a day. Not because it is “digital”. Because the bookkeeper does not open three tabs to answer “is that invoice in yet, and has the tax office sent anything”.
Correcting notes have not been issued in KSeF or outside it since 1 February 2026 — the provisions were repealed, and the ministry says so on the scope page. Pro forma invoices, internal invoices, internal vouchers, credit memos and debit notes are not sent to KSeF. If your client portal has an “issue pro forma” button, it must not call the KSeF API. Mixing a pro forma with FA(3) is a classic implementation error. The client thinks they have paid. The system thinks it has issued. The tax office sees nothing.
A Tuesday morning in the practice: twelve VAT numbers, one queue
Tuesday, 7:50. The bookkeeper opens the overnight list. Four invoices from a construction company went online; the KSeF numbers are there. Two invoices from an online shop came back with an FA(3) error — no buyer NIP on a marketplace order. One workshop invoice has sat in offline24 since 22:10 yesterday because the shed connection died after a storm; a photo of the service receipt is sitting in a messenger. A client under the PLN 10,000 cap emails: “issue it on paper, KSeF does not apply to us”. Paper is still possible until the end of 2026 at that cap. In January 2027 the same email will be a cost.
The bookkeeper does not decide the cap from memory. They open the NIP card: invoice total for the month, the PLN 10,000 threshold, a flag “episodic relief until 31.12.2026”. If the flag is missing, they phone. If it is there, they issue outside KSeF and mark the document as excluded, with the legal basis from the episodic rules. A year later someone from the tax office will ask why that invoice is not in the system. “Because the client wanted it” is worse than “because in August 2026 monthly sales documented by invoices were PLN 7,400 gross, below the threshold”.
A marketplace without a buyer NIP is a separate track. An invoice to a natural person not carrying on a business is excluded from the duty. You may still issue it in KSeF voluntarily. If the shop puts all B2C through KSeF, the register should mark that as a choice, not as a duty. If it issues outside, mark that too. A mix of “sometimes yes, sometimes no”, with no rule on the card, ends with nobody in December able to say which channel is the real one.
Offline24 from the workshop floor: the bookkeeper does not wait for “when the internet is back”. They see the time of issue, they see the missing number, they set an alert for 10:00. If by 10:00 the number has not arrived, they call the workshop owner and the integrator. In 2026 that call is a favour. In 2027 it is part of the “steps taken voluntarily” that article 189d of the Code tells the authority to weigh. Without an alert nobody will call, because the list has 200 rows and the red only shows after lunch.
In the afternoon a correction arrives. The document being corrected has a KSeF number. The correction must point to it. If you issue a correction under your own number “COR/8/2026” and the link field is empty, the buyer will not catch the pair in their KSeF. A practice that corrects “by eye” because the old number fitted in the accounting package leaves a hole. The hole shows up in SAF-T, where from 1 February 2026 the JPK_V7M(3) and JPK_V7K(3) structures are to carry the KSeF number where it applies. We do not quote SAF-T fine amounts here — Infor did not give them in this piece. We quote the field duty.
Questions for the software vendor and the API integrator
Before you renew a subscription or order a “KSeF 2.0” plug-in, sit with the vendor for an hour. Not a demo. Concrete answers you can put in the meeting note. If the vendor says “we are compliant with the rules”, ask for the environment number, the FA(3) version and the date of the last offline24 test. Compliance without a date is a slide.
The questions below are an implementation checklist, not decoration. Put them to the API integrator and, separately, to the accounting-package vendor. They are often two companies.
- Does issuing go through the KSeF 2.0 API or through an intermediate gateway? Who administers the certificate?
- How does the system mark offline24 and an outage announced by the ministry? Are those two different statuses?
- How long does a retry take after a 4xx and a 5xx error? Is there a cap on attempts, or does the queue grow without limit?
- Does an FA(3) schema rejection come back to the bookkeeper with a code, or only with the word “error”?
- Where does the permission list live: in your panel, in the Taxpayer Application, or in both? Who revokes access on the day the client contract ends?
- Is purchase-invoice retrieval batch (once a day) or incremental? What about an invoice that arrived at 23:50?
- Are invoice attachments supported, and do you remember the e-Tax Office notification?
- How do you export the document card to PDF for a tax-office request: which fields, what timestamp?
- What happens on 1 January 2027 to tokens if the client has not moved to a certificate in time?
- Who pays for API downtime: the integrator, the host, the practice, the client?
The last question is unwelcome in a sales meeting, which is why it is worth asking. An SLA with a response time “on working days” is no use on New Year’s Eve if the certificate dies on 31 December. A practice that serves shops and restaurants issues invoices at the weekend too. An integrator who does not answer the phone on Saturday is not a partner for 2027. That can be written into the contract. It cannot be “figured out later”.
If the accounting-package vendor says KSeF “is in an extra paid module”, add that module to the year cost before you compare it with your own panel. The plug-in price does not cover mapping permissions for 80 VAT numbers or a portal in which the client approves a draft. Those are two different services. We write about this honestly when choosing off-the-shelf software or a custom build: SaaS when the model is standard; custom when it does not fit the box.
When SaaS is enough and when you need custom software
A standard practice: a few dozen clients, one accounting package, invoices issued by the client or the practice in the same program, no in-house shop and no field crews with phones. A ready KSeF integrator plus the portal you already have is often enough. We do not burn that on principle that “we would write it better”. GESOFT then says: stay with the vendor, add the fields from the list above, come back to us when a permission or an attachment breaks.
Your own panel starts to make sense when there are hundreds of VAT numbers, when some clients issue from Android on a building site, when others have B2B with individual rates and an attachment, when permissions rotate every month on seasonal contracts, when e-Delivery, KSeF and GDPR consents should hang on one person’s card. Then glueing three SaaS products together ends in a handmade spreadsheet. A spreadsheet will not survive a January 2027 request, because it has no log of who changed the row.
The stack we use is known: Laravel, Vue, Android. We described it with CRM panels. It is not magic. It is ours, so an “offline24 mode” field can be added without waiting for an American vendor’s roadmap. The quote depends on the number of VAT numbers, on whether you wire into an existing accounting package, on whether the field app is to issue or only to photograph delivery notes. Ranges and price components are in how much a Laravel application costs. We do not invent figures here.
We do not replace the finance and accounting package, KSeF or the e-Delivery mailbox on biznes.gov.pl. We build the layer the office will not give you: a practice register across many VAT numbers, with the contract, the permission and the send trail. If your accounting package already has that and survived April 2026 without anyone typing KSeF numbers by hand, stay. If the bookkeeper pastes the number from a notepad, do not stay.
What to do in the practice by the end of 2026
August 2026 leaves you four months without article 106ni fines. In that window you can still mix up a mode and fix the procedure before the mix-up becomes a decision. The order below is a working one. You can spread it across weeks in the team calendar.
September: a permissions review. For each NIP — who may issue, who may read, the certificate end date. Revoke accounts of people who are no longer in the firm. Grant the practice permission where the contract says you issue, and take it off where the client issues themselves. Take a snapshot or an export from the Taxpayer Application and put it in the client file. A paper snapshot is worse than a panel, but better than nothing.
October: an offline24 test in an environment where testing is allowed, and one controlled production test with a client who agrees. Record the times. Check whether the QR code on an offline invoice is where the buyer needs it, before the KSeF number arrives. For CEIDG businesses from 2024 and earlier — an e-Delivery address from 1 October 2026. Do not mix that activation with the KSeF certificate. Two applications, two logins.
November: mapping exceptions. B2C, cash registers, the PLN 10,000 cap, OSS, SME, VAT RR from April 2026 (optional, with a separate FA_RR(1) schema, a duty only where the flat-rate farmer names the buyer in KSeF). Every exception on the NIP card with the date from which it applies. December: certificates instead of tokens, expiry alerts, one dry run of exporting the document card in the shape of a tax-office request. 2 January 2027 is too late for the first export.
In client contracts add three sentences to an annex if they are not there. Who issues invoices in KSeF. Who is responsible for the certificate. In what time the client reports a fault in their own sales software. The annex will not lift the fine off the taxpayer. It will lift off you the complaint “the practice was supposed to watch this” when the client spent a month issuing outside the system and said nothing.
The Infor report of 23 August does not describe a KSeF inspection. We have the rule on the head of office’s decision and the article 189d catalogue. A working scenario: a letter arrives in the client’s electronic delivery address, the attorney in the practice sees it, and asks for documents from the period.
The letter lists three invoices. Two have KSeF numbers, one does not. You open the cards. First: online mode, number, session, bookkeeper Anna K., certificate valid. Second: offline24, issued Thursday 21:14, transmitted Friday 08:02, number assigned, a screenshot of “no connection” from the driver’s phone. Third: status rejected, FA(3) error code, three attempts, last one on Saturday; the client did not correct the buyer’s NIP; in the comment a Monday email “we will send it when I am back from holiday”. The holiday ran until Wednesday. In 2026 that description is awkward. In 2027 it is material for scaling — or for a fine.
You attach an export to the reply, not a story. PDFs of the cards, the session log, a copy of the email to the client with the date. If the authority asks about frequency, you export from the register the number of rejections for that NIP in the last three months. If it asks about benefit, you do not guess. Either there was none, and you write that, or there was a VAT delay and it shows in the return. An invented benefit of “zero, we did not mean to” is worse than silence.
A power of attorney to appear before the tax office is not a KSeF permission. You can hold a UPL-1 and have no right to issue an invoice. You can have the right to issue and no UPL-1. In the client file those two documents sit side by side and people still mix them up. In January 2027 the mix-up will surface in the first call with an official who asks for a power of attorney for explanations and is handed a print-out of KSeF permissions.
The August ministry reply does not move 1 January 2027. It does not cut 100% and 18.7%. It does not add a new mode beside offline24. It does not shift liability from the taxpayer to the practice. It does not order you to replace the accounting package. It confirms that the Code of Administrative Procedure will be used to scale fines, that force majeure allows a penalty to be dropped, and that 2026 is to be a period without article 106ni administrative fines and without fiscal-criminal liability for incorrect use of KSeF.
On the daily invoice the NIP still counts, the date of the supply, the rate, the deadline of the 15th of the following month in article 106i(1) of the VAT Act, the FA(3) schema, the KSeF number after acceptance. A practice that waits for “softer sanctions, because an MP asked” is waiting for something the ministry did not announce in this reply. Employers’ associations may come back with another letter. You still have to issue in October, November and December.
KSeF invoice records in your firm are for those three months and for January. If you paste numbers by hand today, start with an automatic status pull. If permissions live on a sheet of paper, move them onto the NIP card. If the client contract is silent on who issues, add an annex. Those are three moves that do not need a new system. The fourth — a panel that ties KSeF, e-Delivery and the portal — you order when the three are not enough. On kontakt say which of them you already have.
This piece rests on Infor’s report of 23 August 2026, on interpellation no. 17163 of 14 May 2026, on the KSeF duty-scope page and the KSeF 2.0 roadmap, and on the e-Delivery timetable at biznes.gov.pl. Fine amounts other than 100% of VAT and 18.7% of the total due are not here, because the ministry did not give them in this reply. There is also no “how many invoices you may get wrong” limit. We do not add one.
The KSeF number on the transfer and matching receipts from 2027
The Tax Administration Chamber in Wrocław, reporting the KSeF rollout plan, listed three reliefs until the end of 2026: cash-register invoices remain, there are no fines for KSeF invoicing errors, and there is no duty to quote the KSeF number in payments for e-invoices, including under the split-payment mechanism. The notice: Krajowy System e-Faktur – plan wdrożenia. Those three points end on 31 December. From 1 January 2027 the number in the payment title stops being an option your practice will “add once we get used to it”.
In receipt matching it looks like this. A client — a wholesaler with 40 transfers a day — today pastes their own invoice number in the title, or “goods as per delivery note”. The bookkeeper pairs by amount and date. When two transfers share an amount, they phone. From 2027 a VAT-registered payer must, where the Act requires it, add the KSeF number or a collective identifier. If your accounting package matches only on your own number, and the KSeF number is in neither the title nor the receipt card, you get a queue of “unallocated” items. That queue is not an article 106ni fine. It is two days of a bookkeeper’s time before SAF-T.
A register that will survive this keeps, on the sales invoice, the KSeF number in a field you can copy into a transfer. On a purchase invoice — the number from KSeF, not from the PDF the client emailed. On a receipt — the raw bank title, without the bookkeeper “tidying it up”, because that is the title the tax office will see. Split payment remains split payment. The KSeF number does not replace the VAT account. It sits beside it.
A practice that runs 80 sole traders on a lump-sum tax and 20 companies on full books has two tempos. The lump-sum trader worries less about JPK_V7. The company worries about the pair: invoice in KSeF, transfer without a number, a purchase with a number that is not on the statement. On the client card a flag: “from 2027 we require the KSeF number in the title / the client pays from a bank app that truncates the title to 20 characters”. The second case is common in mobile banking. If the bank cuts a 35-character number, you need a collective identifier or another field the Act provides — and a test with that client’s bank, not the integrator’s slide.
Until the end of 2026 it is worth a dry run: for a month add the KSeF number to transfers for three clients who agree, and measure how many receipts the bookkeeper pairs without a phone call. If the result is poor, the problem sits in the bank or the accounting package, not in “low KSeF awareness”. Awareness will not lengthen the title field. A statement integration will.
The invoice on the 15th of the month, the till and the flat-rate farmer
The issue deadline in article 106i(1) of the VAT Act — as a rule no later than the 15th of the month following the month of supply or performance — did not disappear because of KSeF. 15 September in a practice closing August is a crush with or without fines. KSeF adds an API queue to the crush. If 80 invoices go out at 21:40 on the 15th and the session dies, that is what offline24 is for. A draft in the accounting package is not. A draft is not an issue.
Cash registers: until the end of 2026 taxpayers required to use KSeF may still issue electronic or paper invoices at the till, and receipts with the buyer’s NIP treated as simplified invoices (up to PLN 450 or EUR 100). That is what the duty-scope page says. In the register each such sale needs a flag “till / receipt with NIP / outside KSeF until 31.12.2026”. On 2 January 2027 that flag should burn out or move to another mode if the episodic rules end. Do not leave it as an eternal exception, or in March 2027 the bookkeeper will issue a receipt with a NIP and assume “that was always allowed”.
VAT RR and VAT RR CORRECTION: from 1 April 2026 you may issue them in KSeF; you need not. The FA_RR(1) schema is separate. A duty arises when the flat-rate farmer names the buyer in KSeF as authorised — until that nomination is withdrawn. A practice that serves a buying-in desk must keep on the farmer-supplier card: whether they nominated, from when, whether they withdrew. Without that the buyer issues RR outside KSeF while the farmer waits in the system. A dispute over twenty zloty on an RR invoice can take longer than issuing an FA(3) for a limited company.
The issue date in the invoice body and the date sent to KSeF under offline24 — the Wrocław chamber, on the rollout plan, stressed unification: the issue date is to match the date the issuer put in the content, whether the mode is online or offline24. In the panel record those two dates separately all the same. Unifying the legal effect does not mean the technical log has one column. The technical log is for the fine and for scaling. The legal effect is for VAT.
The ministry’s KSeF mobile app remains a free tool for the taxpayer. A practice may recommend it to a sole trader who issues three invoices a month and does not want your Android. It must not “absorb” it into the client portal. That app belongs to the ministry. Your field app — if we build one — is for delivery notes, photos and a draft that later goes to the API. Mixing those two icons on a workshop owner’s phone ends with a double document or none.
The invoice-issuer certificate, which you have been able to apply for since 1 November 2025, the ministry described as an authentication tool needed, among other cases, in an outage and in offline24. In a practice the client’s certificate and the practice’s certificate (when you issue in someone else’s name) must not sit in one folder labelled “certificates” without a NIP tag. Swapping the file on send is an error the API will not explain in human language. A NIP tag, an end date, the password in a safe not in an email — that is a procedure, not a feature.
Frequently asked questions
- When do administrative KSeF fines start?
- On 1 January 2027, under article 106ni of the VAT Act. Those fines do not apply until the end of 2026. In its reply to interpellation no. 17163 the ministry added that in 2026 article 106ni also excludes fiscal-criminal liability for incorrect use of KSeF.
- How high is the fine for an invoice outside KSeF?
- The Act provides for a fine of up to 100% of the VAT shown on the invoice, or up to 18.7% of the total amount where the invoice shows no VAT. Those are maximum rates. The head of the tax office sets the amount in the case, scaling it under, among other rules, article 189d of the Code of Administrative Procedure.
- Will the Ministry of Finance cut those caps before 2027?
- In the reply reported by Infor on 23 August 2026 the ministry said that the calls for lower caps, scaling, protection where the cause is beyond the taxpayer’s control, and a priority for education are already reflected in the Act. There is no announcement in that text of a cut to 100% or 18.7%.
- Who pays the fine: the accountancy firm or the client?
- The taxpayer. The practice bears contractual liability if the contract requires it to issue or transmit invoices. KSeF does not shift the fine onto the practice by operation of law. The contract and the permission log are for settling matters between you and the client.
- What is offline24 mode?
- A mode under article 106nda of the VAT Act. It is used, among other cases, when network quality or a lack of internet makes it hard to issue and send an e-invoice. The ministry points to it as protection where the cause is beyond the taxpayer. It is not the same as force majeure.
- Do KSeF invoice records replace the Taxpayer Application?
- No. The Taxpayer Application and the KSeF 2.0 API remain the official channel. The practice panel keeps a trail: number, mode, who sent, which certificate, whether the document is excluded from the duty. It does not issue “instead of” the ministry system.
- Who must issue in KSeF in 2026?
- From 1 February 2026, taxpayers whose 2024 sales exceeded PLN 200 million. From 1 April 2026, everyone else, except those whose sales documented by invoices do not exceed PLN 10,000 gross a month — they need not issue in KSeF until the end of 2026. Receiving invoices through KSeF has been mandatory from 1 February 2026.
- How does e-Delivery relate to KSeF fines?
- A decision of the head of the tax office will arrive at the e-Delivery address if the client has one. Sole traders in CEIDG from before 2025 must have an address from 1 October 2026. Neither the practice panel nor KSeF replaces the e-Delivery mailbox.
- Will GESOFT replace the finance and accounting package?
- No. We build a register, permissions and client-portal panel beside the accounting package and beside KSeF. If a ready integrator is enough, we will say so in the quote. Custom work (Laravel, Vue, Android) when the practice model does not fit a plug-in.
- How do we request a quote?
- Through the form at /kontakt. Give the number of VAT numbers, who issues invoices, which accounting package you use, and whether you hold KSeF 2.0 certificates. A quote comes back within 24 hours.
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