The National e-Invoicing System is a state system for issuing, receiving and storing structured invoices.
An invoice will no longer be merely a PDF file sent by e-mail. An invoice issued in KSeF goes to a central system and receives a special identification number.
In a limited liability company it is the entity that logs into the system – and it is the management board that is responsible for deciding who may issue, receive and view invoices on behalf of the company.
From when does KSeF apply to limited liability companies?
From 1 February 2026 companies have to reckon with the fact that some purchase invoices will be available in KSeF, especially from larger counterparties.
From 1 April 2026 the obligation to issue invoices in KSeF covers most of the remaining taxpayers, including limited liability companies.
For the smallest entities a temporary exception has been provided – if the value of sales documented by invoices in a given month does not exceed 10 000 zł gross, invoices may be issued outside KSeF until the end of 2026. Once the limit is exceeded, the obligation to issue invoices in KSeF arises as of the invoice that exceeded that limit.
How does a limited liability company gain access to KSeF?
There are two routes:
- if the company has a qualified electronic seal with its tax identification number (NIP), it can log in with it directly – without any additional formalities towards the tax office,
- if there is no seal, a ZAW-FA notification has to be filed with the tax office, naming a natural person (e.g. a member of the management board, an accountant) who will be the first to obtain administrative access to the system on behalf of the company.
The person named in the ZAW-FA logs into KSeF with a Trusted Profile or a qualified signature, and then – with no further paper filings – grants further rights electronically within the system itself: to other employees, to further members of the management board, and also to other entities, for example to an accounting office.
A multi-member management board – what to keep in mind
Where the board has several members, it is worth deciding up front who is the first administrator of the system and whether the remaining board members are also to receive access. It is good practice not to grant the rights to one person only – leave, illness or a change in the composition of the board should not block the issuing or receipt of invoices.
A change in the composition of the board is also a signal to review and update the rights in KSeF – they do not change automatically.
How to arrange cooperation with your accounting office
Until now many companies sent invoices to their accounting office by e-mail, through a client panel, or handed them over on paper. In KSeF this flow changes – the document lives in the system, not as an attachment to an e-mail.
That is why it is worth settling in advance:
- who in the company issues the sales invoices,
- who receives the cost invoices,
- whether the accounting office is to receive direct access to KSeF as an authorised entity,
- whether the invoicing software used in the company supports KSeF and several users at once.
Who is responsible for access to the invoices?
The company – represented by its management board – is responsible for issuing invoices and for granting the right permissions in KSeF. Without this, the accounting office may have no way of downloading the documents from the system.
Fengo Sp. z o.o. | Accounting Office | Cieszyn
www.fengo.pl | biuro@fengo.pl
