Stamp or qualified signature for KSeF? A short decision

Arrange KSeF access wisely: company seal (TIN) for permanent login and integration, qualified signature for named actions. Check out ready-made examples and a checklist for the CFO / COO.
Stamp or qualified signature for KSeF? The short decision.

KSeF without secrets - what is it and why do we need it?

KSeF (National e-Invoice System) is a state-run "intermediary" between invoice issuers and recipients. Instead of sending PDFs to each other, companies send a unified data file (XML). KSeF assigns it a number, confirms delivery and... keeps order.
The result? Fewer errors, fewer emails with attachments, easier automation in accounting.

KSeF - the National e-Invoicing System - is a state-owned platform for issuing, receiving and storing structured invoices (XML in a specific structure). Once an invoice is sent to KSeF, the system assigns it a unique number and stores it as the "sole source of truth." This results in a consistent format, fewer errors and automation of circulation between companies and accounting. It's also part of the broader digitization of VAT accounting in the EU.

Structured data - what is it all about?

Imagine an invoice like a cardboard box with compartments. Each item (TIN, date, VAT rate, total) has a a specific compartment. The accounting program does not "read the picture", but immediately takes data from the right places. This is what is meant by "structured data".

What problems does KSeF solve?

  • Authenticity and integrity - Guaranteed by the system itself (KSeF number + storage on the MF side), not by "dosed PDFs". (Gov.pl)
  • Fewer disputes over "whether it has arrived / in what version" - statuses and UPOs from KSeF confirm delivery and processing. (Gov.pl)
  • Automation of accounting - Unified structure (currently FA, and with mandatory implementation - FA(3)) facilitates ERP integrations. (National e-Invoice System)

 

What is the mysterious "FA(3)"?

 

This version of the scheme Of this "partitioned" invoice. That is, the form issue number, not the new document type. When you hear FA(3), think: "OK, the current data box pattern."
You don't have to "do anything with FA(3)" manually - this is handled by the systems (ERP, integrations), it is only important that they are updated.

Who will KSeF cover and from when?

 

The obligation enters in stages:

  • As of February 1, 2026. - Entrepreneurs whose gross sales value in 2024 exceeded PLN 200 million, must issue invoices in KSeF. As of this date all VAT taxpayers (including exempt ones) must be ready receive invoices through KSeF. (Gov.pl)
  • As of April 1, 2026. - other entrepreneurs must issue KSeF invoices. (Gov.pl)
  • Starting January 1, 2027. - There is a provision for a shift for the smallest entities (sales of up to about PLN 10,000 - announcement on KSeF website). (National e-Invoicing System)

Until these dates, KSeF can be used voluntarily. The key is to prepare the system, people and authorizations so that the launch does not surprise the company. 

Important! Invoices for consumers (B2C) remain outside the obligation to issue in KSeF (you can voluntarily), but if you conduct B2B sales - the obligation will cover you according to the thresholds/dates. Foreign entities without a permanent place of business in Poland are excluded from mandatory issuance. (Interpretations)

 

Is it necessary to sign every e-invoice with a qualified signature?

Don't. In KSeF you don't affix a signature to every invoice. Authenticity and integrity is taken by the system itself (KSeF number, delivery path and storage).
The signature/qualified seal is used for logging in and authorization and granting authorizations - and not for signing the invoice file itself.

What's better for KSeF work: a stamp or a signature?

Briefly

  • Qualified Seal (QSeal) - best as a "corporate identity": stable login on behalf of the organization, convenient for ERP integrations, does not bind the process to a specific person.
  • Qualified signature (QES) - essential for people: granting/revoking authorizations, named actions, ad-hoc situations (deputy's vacation, one-time actions).

Why does the seal often win in its daily work with KSeF?

  • Constancy and automation: The seal "belongs to the company," so you don't have to rewrite certificates when someone changes positions.
  • Integrations: It is easier to hook it up to external systems (ERP/finance) that run 24/7 without a person.
  • Less paperwork: with the TIN stamp no need to submit a ZAW-FA; you have what is known as owner's rights in KSeF. Form ZAW-FA is submitted only if the company does not have a qualified seal with a TIN and must designate a person authorized to act in the KSeF.
  • If you have qualified stamp with NIP, you benefit from original ownership rights i you do not have to file a ZAW-FA. When changing the accountant usually simply revoke and grant new authorizations in the system - no paper authorizations.

So why the signature (QES)?

  • Name actions: someone "flesh and blood" must add a user, revoke access, confirm role changes.
  • Flexibility: when the process is sporadic (owner, CFO), QES is enough to step in and do a specific action.
  • Note on names: "personal" vs. "business" is mainly a order in paperwork; KSeF checks anyway powers granted.

Does "personal vs business" matter?

  • For mere access to KSeF - no. What matters are permissions in the system.
  • For the sake of order and audit - yes, it can be convenient at times: a certificate with attributes of the company is easier to link to a person's business role in internal documentation. This is a plus in large organizations.

When can the QES itself be a problem?

When you base dp KSeF access solely on one person, then turnover or absence of an employee - means downtime.

Recommendation podpisano.pl (practical set)

  • 1-2 QES (signature) For key people (management/finance) - for named and emergency actions.
  • 1 QSeal with TIN (seal) for organizations - For permanent login "company" and under integrations.
  • Written down, brief authorization policy: who grants/receives access in KSeF, who uses the seal, how we operate in emergency mode.

You can read more about the differences between e-signatures and business signatures here here.

Mini-FAQ

Is KSeF already working "hard"?
The obligation to exhibit is postponed: large from 1.02.2026, others from 1.04.2026. Receipt from large - from 1.02.2026 for all VAT payers. Until the dates indicated above, you issue invoices as before (paper/PDF/EDI), and you can use KSeF voluntarily.

Do I have to sign every invoice?
No. The signature/stamp is used for login and authorization, not for "docking" to a file.

Will B2C also enter the KSeF?
As of today there is no obligation to invoice consumers in KSeF (you can voluntarily).

Is it better to have a "business" signature than a "personal" one?
For access - no difference, what matters is powers. For order and audit in larger companies -. "business" with company attributes is sometimes more convenient ..

What if the Internet or the system "goes down"?

Then there are two modes available:

  • Offline mode - you issue an invoice outside KSeF and upload it to the system after the obstacle ceases to exist (the deadlines for uploading result from the law/FAQ MF. MF act/FAQ),
  • failure mode - if it's a failure on the KSeF side, there are longer windows for backhaul.
    Detailed dosage deadlines: 7 working days after the KSeF failure (system failure) or the next business day at the latest (other obstacles). (National e-Invoice System)

Recommendation podpisano.pl

  • Yes, it is worth having a QES for key people (e.g. SimplySign - mobile or Certum Mini - USB card).
  • Yes, it is worth having a qualified seal (QSeal) For organizations - simpler "corporate" login and preparation for automation.
  • Yes, it is worth taking care of system updates - so that FA(3) and KSeF statuses are handled without surprises.

Need to select a qualified kit: signature+seal under KSeF? Let us know - at podpisano.pl we do this on a daily basis and we will prepare a short checklist for you on how to make a set.

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