Who is affected by the National e-Invoicing System?
Currently, the issuance of structured invoices within the National e-Invoicing System is mandatory:
- For taxpayers whose sales in 2024 exceeded PLN 200 million,
- For other taxpayers, unless their sales value for monthly periods does not exceed the amount of PLN 10,000 gross.
This state of affairs will continue until the end of 2026. As of January 1, 2027, the smallest companies – including those selling for less than PLN 10,000 gross – will also be required to issue invoices in KSeF.
Important!
Above we discussed the obligation to issue structured invoices. By now, all taxpayers must be ready to receive invoices in the National e-Invoice System.
Types of permissions in KSeF. How to manage permissions?
Key in this regard are:
- KSeF entitlement definition,
- types of authorizations to use the National e-Invoicing System,
- Ways of granting and revoking rights.
All these aspects are regulated by the Decree of the Minister of Finance and Economy dated December 12, 2025 on the use of the National e-Invoicing System.
According to §3.1 of the aforementioned document, the rights to use the National e-Invoicing System are the rights to:
- To grant and revoke rights to use the KSeF,
- Issuing and accessing structured invoices and electronic invoices (issued during the period of KSeF failure and during the period of KSeF unavailability),
- issuance of invoices by the buyer of goods or services
- Issue VAT RR invoices and VAT RR CORRECT invoices in KSeF.
Some of the powers mentioned above – to grant and revoke authorizations to use KSeF and to issue and access structured and electronic invoices – are held by:
- taxpayer,
- entities referred to in Article 106c of the VAT Law, viz:
- Enforcement authorities during administrative enforcement proceedings,
- court bailiffs performing enforcement activities as defined in the Code of Civil Procedure),
- an individual designated by the taxpayer (and also by representatives of the taxpayer’s internal units, local government units or VAT groups)
- an individual designated by an individual with the authority to grant and revoke KSeF,
- a non-individual entity designated by the taxpayer – most often an accounting office,
- an individual designated by an entity designated by the taxpayer (e.g., a specific employee of the accounting office, who was previously given the appropriate authority by the taxpayer).
Important!
The use of the KSeF is based on an entitlement model. Initially, only the taxpayer, or in the case of a sole proprietorship, the business owner, has full (proprietary) rights. Thanks to them, he can:
- manage permissions,
- issue invoices,
- view issued invoices.
In order for KSeF to be used on behalf of your company by employees, accountants or others, you must first give them permissions. So if you don’t run the company yourself, the sooner you grant permissions to the appropriate individuals or entities, the better.
How do I grant or revoke access to KseF?
Currently, granting and editing permissions to use the National e-Invoice System is possible in two ways.
Electronically – a taxpayer or authorized person can use the KSeF Taxpayer Application or software integrated with KSeF to grant, change or revoke authorizations to a designated person.
In the traditional form – the taxpayer or person of entitlement can submit notices of granting or revoking KSeF entitlement to the competent head of the tax office. To do this, use the ZAW-FA form, fill it out and submit it to the office. However, this form is provided only for taxpayers and entities that are not individuals and do not have the ability to authenticate with a qualified electronic seal.
Granting rights to KSeF through the Taxpayer Application.
How do you grant KSeF permissions to an accounting office or employee? Follow these few steps:
- Visit the KSeF Taxpayer Application page.
- Log in using one of the available methods:
- trusted profile,
- mCitizen application,
- e-Evidence,
- electronic banking,
- qualified signature,
- e-stamp.
- In the Taxpayer Application, select the Entitlements module.
- Fill out the authorization form:
- Select the type of entity or entity first,
- Complete the data of the authorized entity (TIN or PESEL, first and last name).
In this way, you can give permissions to KSeF:
- subjects of the current context,
- To subordinate units identified by an internal identifier,
- Subordinate entities identified by the TIN,
- EU entities entitled to self-invoicing identified by an EU VAT number.
Important!
If the entity you want to authorize is an individual using a certificate that does not contain a TIN or PESEL identifier, you will need to enter additional information, including:
- birth dates,
- type of identity document,
- The number and series of the aforementioned document,
- country of issuance of the document,
- certificate fingerprint.
How do I grant KSeF privileges to an accounting office?
If your company uses the services of an accounting firm or a bookkeeper who is in business, you can easily authorize the appropriate people to both view and issue invoices in KSeF.
How does it work in practice? Here’s an example.
Example:
Mr. Ireneusz runs a sole proprietorship in which he issues VAT invoices. As of April 2026, the entrepreneur is required to issue structured invoices in the National e-Invoice System.
Just a few weeks before the System was implemented in the company, Mr. Ireneusz decided to empower the accounting office with which his company has been working for many years.
The upshot: by granting authority, the accounting office (and therefore all its employees) can issue invoices structured in KSeF on behalf of Mr. Ireneusz’s company.
And what if the entrepreneur wanted more control and fewer people who can see the invoices issued and can issue sales documents in the System? There is a way to do this as well.
Example:
Mr. Ireneusz wants only a trusted employee of the accounting firm his company uses to issue invoices on behalf of his company. He is satisfied with the cooperation with this particular person and cares that only this person should have insight into his company’s documents.
An idea worth considering is to empower not one, but at least two people – this way, in the event of illness or vacation of a designated accounting office employee, the other will be able to issue invoices on behalf of the company, ensuring continuity of service.
Keep in mind, however, that each additional person given access to KSeF is not without impact on your company’s security. This, plus the continuous access to the KSeF Taxpayer Application, means that you might as well give privileges to one person, and only extend them to another if necessary.
Entitlements to KSeF: how to receive them?
One of the most important functions in the context of permissions is the ability to revoke them. This is primarily about maintaining control and security within the company.
In what situations should privileges be revoked?
- When a KSeF-eligible employee leaves or is dismissed from the company.
- When an accounting office employee authorized to use KSeF changes jobs.
- When you end cooperation with an accounting office. At that time, remember not only to revoke the authorizations for the entity, but also for all the employees of the office who were previously given authorizations.
- When an employee who used to invoice is transferred to another department and will no longer actively use KSeF.
What are the mistakes to beware of?
A popular mistake is leaving privileges to people who no longer need them. This compromises the company’s security – not least because of the possible detriment to the company of a person who still has privileges (even though he shouldn’t have them).
This can also make a difference when a company is trying to figure out where specific movements in KSeF came from. The more people who are authorized to invoice, the more time it will take to verify.
Remember, too, that permissions regarding access to invoices are also important. Those with such access can view and download invoices, and thus know about all transactions your company makes.
Summary
KSeF permissions for an accounting office is a key issue in the context of complying with the obligation to issue structured invoices. If your company uses the services of an accounting firm, granting the appropriate permissions should be one of the first steps you take – only after this step is taken will accountants be able to issue invoices on behalf of your company and gain access to view documents.
Remember, too, that you can revoke permissions at any time – as soon as they are no longer needed by a particular entity or person. Use this option to keep control of your invoicing and keep your company safe.
