KSeF 10,000 PLN limit: how to count it
The 10,000 PLN limit is counted per month, on gross amounts, and only from invoices to businesses. If you cross it even once, the invoice that crossed it and every invoice after it must go through KSeF (Krajowy System e-Faktur, Poland's national e-invoicing system).
Legal position as of 7 October 2026.
What the limit is
Art. 145m ust. 1 of the VAT Act gives a temporary exemption from issuing invoices via KSeF to taxpayers whose sales documented by KSeF-liable invoices do not exceed 10,000 PLN gross in a calendar month. The exemption ends on 31 December 2026. It is a buffer for implementation, not a permanent carve-out for small businesses. The threshold applies to every taxpayer who issues invoices, VAT-exempt ones included (Art. 113), whatever their VAT status.
Ustawa o VAT art. 145mHow to count it
- Calendar month. Not a year, not a quarter. The counter resets on the first day of the month.
- Gross amounts. An invoice for 8,000 PLN net plus 23% VAT counts as 9,840 PLN.
- Only B2B invoices subject to KSeF. Not your total revenue.
- Issue date. What counts is the month in which the invoice is issued, not the sale or service date.
Example: Ania, freelance graphic designer
Ania runs a sole proprietorship (JDG) and invoices agencies and studios. In March 2026 she has three invoices:
| Invoice | Client | Gross amount | Running total |
|---|---|---|---|
| No. 1 | Studio AABB | 3,200 PLN | 3,200 PLN |
| No. 2 | Agencja XYZ | 2,800 PLN | 6,000 PLN |
| No. 3 | Sklep Online | 2,500 PLN | 8,500 PLN |
She is below the limit, so she can still invoice outside KSeF. Mid-month she takes a new project:
| Invoice | Client | Gross amount | Running total |
|---|---|---|---|
| No. 4 | Drukarnia ABC | 2,000 PLN | 10,500 PLN |
The total passes 10,000 PLN, so invoice No. 4 itself must go through KSeF.
There is no grace period after crossing the limit (Art. 145m ust. 2 of the VAT Act). An invoice that crosses it and is issued outside KSeF is issued in breach of the rules.
What doesn't count
- B2C invoices, issued to individuals not conducting business.
- Fiscal till sales (receipts).
- Cash register invoices and receipts with a buyer's NIP (tax ID) up to 450 PLN gross (or 100 EUR), outside KSeF until 31 December 2026 (Art. 145n of the VAT Act). From 1 January 2027 a cash register can no longer issue invoices, and a receipt with a NIP stops counting as a simplified invoice.
- Other documents excluded from KSeF by specific provisions.
With mixed sales, only B2B invoices enter the count. Your total turnover can exceed 10,000 PLN a month while you stay below the KSeF limit, and the other way round.
What happens after you cross it
From the invoice that pushes you over 10,000 PLN gross, KSeF is mandatory immediately. You cannot return to PDFs even if sales drop in later months. Cross the limit in March and in April you are in KSeF even for a single 800 PLN invoice.
When the exemption ends
From 1 January 2027, KSeF is mandatory for every taxpayer who issues invoices, active VAT payers and VAT-exempt ones alike, regardless of turnover or invoice count.
Common misconceptions
"I'm on ryczałt, so this doesn't apply to me." Ryczałt is a form of PIT (income tax) settlement and does not change the duty to issue invoices in KSeF. The threshold applies to every taxpayer, VAT-exempt ones included, so the same rules apply to you as to active VAT taxpayers.
"My earnings are low, so I'm under the limit." The limit counts B2B invoices, not income. Several business clients invoiced above 10,000 PLN gross in a month means you are over, even if the rest of your sales go through a till.
Tracking the limit
A good invoicing application shows the total of invoices issued this month and lets you separate B2B from B2C and till sales. With mixed sales, ask your accountant how to count it in your case. If you are approaching 10,000 PLN, start implementing KSeF early, because after crossing there is no way back.
You can rehearse on MF's test environment, where invoices with dummy data have no legal effect. If your software generates the XML, you can check the file on ksefuj.to; it never leaves your browser.
FAQ MF — KSeF 2.0Next step
For what changes from April, see KSeF from 1 April 2026, and for the practical minimum for sole traders, KSeF for sole traders.
Sources
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