Flat-rate tax doesn't exempt you from KSeF

Paying income tax under ryczałt ewidencjonowany (Poland's flat-rate tax on recorded revenue) neither exempts you from KSeF (Krajowy System e-Faktur, Poland's national e-invoicing system) nor changes anything in it. Ryczałt is a form of income tax (PIT), while the KSeF obligation comes from the VAT Act, so what decides whether you issue invoices in KSeF is your VAT status and whether the invoice goes to a business or a private person.

Legal position as of 10 November 2026.

Why your income tax form doesn't matter

Art. 106ga ust. 1 of the VAT Act says: „Podatnicy są obowiązani wystawiać faktury ustrukturyzowane przy użyciu Krajowego Systemu e-Faktur” (taxpayers must issue structured invoices using KSeF). The exceptions in ust. 2 of that article cover, among others, businesses with no seat in Poland, some special schemes (e.g. IOSS), invoices to private persons, and businesses from other EU countries using the art. 113a exemption. None of them refers to how you settle PIT.

VAT Act, art. 106ga (Dz.U. 2026 item 1263)

The MF (Ministry of Finance) FAQ puts it this way: „każdy podatnik (czynny i zwolniony), który ma obowiązek wystawienia faktury, będzie wystawiał ją w KSeF” (every taxpayer, VAT-registered or exempt, who has to issue an invoice will issue it in KSeF). So you first establish whether you have to issue an invoice, and only then whether it goes to KSeF (the KSeF 2.0 Handbook, part II, point 1.2 describes it the same way). We found no MF statement on ryczałt in the context of KSeF. Our conclusion rests on the wording of the Act and the FAQ, where the test is the duty to issue an invoice, not the income tax form.

MF FAQ: KSeF 2.0 MF: KSeF 2.0 Handbook, part II, point 1.2

Ryczałt doesn't mean VAT exemption either. On ryczałt you can be an active VAT taxpayer (czynny podatnik VAT) or use the art. 113 exemption. These are two separate choices.

On ryczałt and VAT-registered

You have the same deadlines as any other business: from 1 April 2026 you issue invoices to businesses in KSeF (from 1 February 2026 this applied only to taxpayers whose 2024 sales exceeded 200 million zł gross).

MF: KSeF 2.0 Handbook, part II, obligation dates

Until 31 December 2026, art. 145m still applies: you may issue invoices outside KSeF if their total gross value in a given month is no more than 10,000 zł. You lose that right from the invoice that takes you over the limit, and you don't get it back in later months. Invoices to private persons don't count towards the limit. We explain how to count it in our post on the 10,000 zł limit. Until the end of 2026 you can also issue invoices from a cash register (art. 145n); from 1 January 2027 that option goes.

MF: below 10,000 zł MF: KSeF 2.0 Handbook, part I, p. 14

Example: Tomasz is a developer on ryczałt and VAT-registered. Every month he invoices one software company 12,300 zł gross. That invoice alone exceeds 10,000 zł, so from April 2026 Tomasz issues it in KSeF. Ryczałt changes nothing here.

On ryczałt and VAT-exempt (art. 113)

Under the subjective exemption (sales up to 240,000 zł net a year) you don't have to issue invoices (art. 106b ust. 2). You must issue one if the buyer asks within 3 months of the end of the month in which you performed the service or received payment (art. 106b ust. 3 pkt 2). A simple receipt (rachunek) won't do instead: the KSeF 2.0 Handbook (part II, point 1.3) explains that when an exempt taxpayer documents a sale, the document is always an invoice.

If you issue that invoice to a business, it goes to KSeF on the same terms as for VAT-registered taxpayers, including the 10,000 zł limit until the end of 2026. The details are in our post on VAT-exempt businesses and KSeF.

Example: Olga is a translator on ryczałt using the art. 113 exemption. In November 2026 a travel agency asks her for an invoice for 2,400 zł. It is her only invoice that month, and she has not exceeded the limit in any earlier month, so she can issue it outside KSeF. The same invoice in January 2027 goes through KSeF.

MF: KSeF 2.0 Handbook, part II, point 1.3 MF: KSeF implementation stages

Invoices to private persons can stay outside KSeF

Invoices to a natural person not running a business fall outside the KSeF obligation (art. 106ga ust. 2 pkt 4), whether you are VAT-registered or exempt. You may issue them in KSeF voluntarily. How to hand such an invoice to the customer is covered in our post on invoicing a private person.

You receive purchase invoices in KSeF

Since 1 February 2026 you receive invoices from suppliers in KSeF. Some may still arrive outside the system, though: until the end of 2026 from suppliers within the 10,000 zł limit and from cash registers, and after 2026 too from foreign businesses with no seat or fixed establishment in Poland. An invoice with your NIP (Polish tax ID) as the buyer appears in the system automatically and you don't have to accept it. The free MF tools, such as Aplikacja Podatnika (the Taxpayer Application), are enough. If you are VAT-registered, the right to deduct VAT arises no earlier than in the period you receive the invoice (art. 86 ust. 10b pkt 1). Our guide to receiving invoices walks through it step by step.

MF: KSeF 2.0 Handbook, part II, points 1.7 and 6.1–6.2

What's the penalty for an invoice issued outside KSeF?

Under the Act currently in force, from 1 January 2027 art. 106ni provides for a penalty of up to 100% of the tax on an invoice issued outside KSeF, and for an invoice showing no tax (as with VAT-exempt sellers) up to 18.7% of the total amount due. MF has announced it will defer penalties to the end of 2027, stressing that „odroczenie kar nie oznacza braku obowiązku stosowania KSeF” (deferring penalties does not remove the obligation to use KSeF). On 6 November 2026 the Sejm passed the act from draft UD477, which moves the penalties to 1 January 2028. The act still awaits the Senate and the President, so it is not yet law.

MF: penalty deferral extended to the end of 2027 Sejm, print no. 3245: legislative progress

„Rolnik ryczałtowy” is something else

„Rolnik ryczałtowy” (flat-rate farmer) is a special VAT scheme (art. 115–117 of the VAT Act), unrelated to ryczałt ewidencjonowany in income tax. Everything above is about ryczałt ewidencjonowany.

If you are not sure whether you are VAT-registered or exempt, check with your accountant. That answer, not ryczałt, tells you which of the sections above applies to you.