KSeF from 1 January 2027 for JDG and small firms: 10 000 zł limit ends

From 1 January 2027 every JDG (sole trader) and every small business issues invoices to other businesses in KSeF, including VAT-exempt traders and those on ryczałt. The exception that until 31 December 2026 allows invoices outside KSeF, as long as their gross total in a month does not exceed 10 000 zł, expires (art. 145m of the VAT Act).

Law as of 20 October 2026.

Penalties do not change the duty itself. On 20 October 2026 the government sent the Sejm a bill that moves KSeF penalties to 1 January 2028, but the 1 January 2027 date for invoices stays. Below: who is affected, what changes in January, what the law says about penalties and what to do before the end of the year.

Who must use KSeF from 1 January 2027

The duty comes from the VAT Act, so neither the legal form nor the PIT tax form matters. The Ministry of Finance states plainly that every taxpayer, VAT-registered or exempt, who must issue an invoice issues it in KSeF.

If you issue no invoices at all, for example you sell only to consumers through a cash register and nobody asks for an invoice, KSeF does not change your sales. Purchase invoices from Polish suppliers reach you through KSeF anyway.

How the 10 000 zł limit works until 31 December 2026

Until the end of 2026 you may issue paper or PDF invoices if the total value of sales with VAT documented by such invoices in a month is at most 10 000 zł. The counting rules according to the Ministry of Finance:

1. Count only invoices that would normally have to be issued in KSeF. Do not count invoices to consumers, invoices from a cash register or receipts with a NIP up to 450 zł.
2. An invoice belongs to the month of its issue date, not the month of the sale.
3. The invoice that takes you over 10 000 zł must already go to KSeF, and so must every later one. Lower sales in the next month do not reverse this.

Example: a graphic designer on a JDG

Anna runs a JDG and is an active VAT payer. In November 2026 she issues outside KSeF an invoice to a business for 4 920 zł gross (4 000 zł net + 23% VAT) and a second one for 3 690 zł (3 000 zł + 690 zł). An invoice to a private client for 1 230 zł does not count toward the limit.

The invoice to business C takes the total over 10 000 zł, so Anna issues it in KSeF, and from then on every later invoice to a business. From January 2027 this choice disappears for everyone.

Details of the limit for companies, permissions and offline modes are in the article KSeF for a sp. z o.o..

What changes on 1 January 2027

• The 10 000 zł limit ends. Every invoice to a business is created in KSeF. An invoice emailed as a PDF outside KSeF no longer meets the duty.
• No more invoices from cash registers. Invoices from a cash register and receipts with a NIP up to 450 zł as simplified invoices stayed outside KSeF only until 31 December 2026 (art. 145n of the VAT Act). The explanatory memorandum to the government bill confirms that from 1 January 2027 issuing invoices from cash registers will not be possible.
• KSeF number in the bank transfer. For payments from 1 January 2027, an active VAT payer who pays another active VAT payer by bank transfer gives the invoice's KSeF number in the transfer title (art. 108g of the VAT Act).
• Invoices for buyers without KSeF access. You give a private client or a foreign business the invoice in an agreed way, for example as a PDF with a QR code that leads to the invoice in the system (art. 106gb ust. 4 and 5 of the VAT Act).

Penalties: what the law says and what the government bill says

Under the law the head of the tax office may impose a penalty of up to 100% of the VAT on an invoice issued outside KSeF, and on an invoice without VAT up to 18.7% of the total amount due (art. 106ni ust. 1 of the VAT Act). Failing the KSeF duty alone does not start fiscal criminal proceedings (art. 106ni ust. 4).

The Council of Ministers adopted the bill moving the penalties on 20 October 2026, and print no. 3245 reached the Sejm the same day. It is a bill, not law: the Sejm and the Senate must pass it and the president must sign it. Even if it takes effect, the explanatory memorandum says the tax administration (KAS) will first remind taxpayers of the duty and then check whether invoices outside KSeF lead to unreliable VAT settlement.

A separate deputies' bill (print no. 2321), which changes the KSeF date for micro-businesses, has been waiting for its first reading since 13 March 2026. Do not plan around it.

What to do before 31 December 2026: 8 steps

1. Count your invoices to businesses for recent months. If you have already gone over 10 000 zł in a month, the duty applies to you today, not from January.
2. Log in to the KSeF Taxpayer Application (Aplikacja Podatnika KSeF). A person running a JDG receives owner permissions automatically and logs in with Profil Zaufany or a qualified signature. The ZAW-FA notification is usually not needed.
3. Check your purchase invoices. Receiving through KSeF applies since 1 February 2026. An invoice counts as received on the day KSeF assigns its number (art. 106na ust. 3 of the VAT Act), and the system sends no notifications.
4. Give permissions to your accountant or accounting office. You can grant the permission to the whole office, and it will name its staff. You share a KSeF certificate issued to you with no one.
5. Choose where you will issue invoices. Free options: the KSeF Taxpayer Application, the KSeF Mobile App or e-mikrofirma in e-Urząd Skarbowy; beyond them, software connected to KSeF. If you issue invoices from a cash register today, from January you issue them in KSeF.
6. Issue a test invoice in the Demo version. The Demo Taxpayer Application uses a real login, but its invoices have no tax effect.
7. Download a type 2 KSeF certificate. Without it you cannot mark an offline invoice with the second QR code when the internet is down. The certificate is valid for at most 2 years.
8. Prepare clients and your bank. Agree with foreign clients and consumers how they will receive a PDF with a QR code. From January you enter the invoice's KSeF number in the title of a transfer to an active VAT payer.

Free KSeF tools

• KSeF Taxpayer Application (online): issuing and downloading invoices, permissions, tokens and certificates. The guide how to issue a KSeF invoice for free walks through it step by step.
• KSeF Mobile App for Android and iOS: issuing and receiving invoices on your phone.
• e-mikrofirma in e-Urząd Skarbowy: JDG only, invoices in KSeF and their transfer to the VAT register.
• KSeF invoice generator: without an account you prepare an FA(3) file that you upload in the Taxpayer Application.

KSeF tokens for accounting software stay without an end date, not only until the end of 2026. The Ministry of Finance has announced an amendment to the regulation on this.

How Norman helps

Norman sends invoices to KSeF and pulls purchase invoices from it. You use it for free for 30 days with no card, and issuing and receiving invoices in KSeF stays free after the trial too. In the JDG plan for 39 zł net a month it keeps the KPiR or the revenue register, calculates PIT and ZUS and prepares JPK_V7, which you approve; a sp. z o.o. gets CIT, VAT and JPK_V7 in the Max plan for 119 zł. You can prepare a single invoice without an account in the KSeF invoice generator, and read about Norman itself on the home page.

If you are weighing whether to stay a JDG as sales grow, see the comparison JDG or sp. z o.o..

Frequently asked questions

Does a VAT-exempt JDG have to issue invoices in KSeF?

Yes, every invoice to a business from 1 January 2027, and already in 2026 with sales above 10 000 zł gross in a month. A VAT exemption does not exempt you from KSeF. Invoices to consumers and the SME scheme exemption stay outside KSeF.

Do I have to use KSeF on ryczałt too?

Yes. KSeF comes from the VAT Act, so the tax scale, flat tax and ryczałt make no difference. What counts is whether you issue invoices to businesses.

Will I pay a penalty for an invoice outside KSeF in 2027?

Under current law penalties apply from 1 January 2027. The government bill of 20 October 2026 (print no. 3245) moves them to 1 January 2028, but until it is passed it is only a bill. The duty to issue invoices in KSeF from January applies in both cases.

Do I have to file ZAW-FA as a JDG?

Usually not. KSeF assigns owner permissions to the person running a JDG automatically, and you log in with Profil Zaufany or a qualified signature. ZAW-FA is needed when your signature contains neither a NIP nor a PESEL.

What about invoices to private clients?

Invoices to individuals not running a business need not go to KSeF (art. 106ga ust. 2 pkt 4 of the VAT Act). You may issue them in KSeF voluntarily and give the client a PDF with a QR code.