When the system is down – offline invoicing, failures, and deadlines

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    Modes of issuing structured invoices

    The KSeF system allows for issuing structured invoices in two main modes: ONLINE and OFFLINE.

    • ONLINE mode involves issuing an invoice and sending its structured version to the KSeF servers in real time.
    • OFFLINE mode allows for issuing an invoice outside the KSeF system and then sending its copy to the KSeF servers in accordance with applicable regulations. This mode includes several procedures:
      • Offline24 mode – this mode allows for sending a structured invoice no later than the next business day after the day it was issued (Article 106nda of the VAT Act).
      • Emergency mode – used when a KSeF failure is officially announced in the Public Information Bulletin of the Ministry of Finance and in the interface software (Article 106nf of the VAT Act).
      • Offline (service) mode – applied in case of KSeF system unavailability, e.g., due to maintenance work (Article 106nh of the VAT Act).

    Offline24 mode

    Offline24 is the Ministry of Finance’s response to real concerns of entrepreneurs regarding the timeliness of sending invoices to KSeF servers, caused by unforeseen circumstances beyond the taxpayer’s control—such as power outages at the company’s premises, internet access issues, or disruptions in commercial systems used for issuing structured invoices.

    A structured invoice issued in Offline24 mode must be sent to KSeF without delay, but no later than the next business day after the day of issuance, in order to receive a KSeF number.

    If the taxpayer fails to send the invoice on time due to a system failure (Article 106nf of the VAT Act), the document may be submitted to KSeF no later than within 7 business days from the date the failure ends.

    The date of issuance of an invoice in Offline24 mode is the date indicated in accordance with Article 106e(1)(1) of the VAT Act, meaning the actual date the document was issued, not the date it was submitted to KSeF (provided the submission occurred on the next business day).

    Example. A taxpayer issued an invoice in Offline24 mode on January 8, 2026. The document was submitted to KSeF on the next business day, January 9. According to the regulations, the date of issuance of the invoice is January 8.

    Emergency mode

    Emergency mode allows the continuation of structured invoice issuance in the event of a KSeF system failure, officially announced in the Public Information Bulletin of the Ministry of Finance and in the interface software.

    An invoice issued in emergency mode must be submitted to KSeF no later than 7 business days after the end of the failure to receive a KSeF number.

    If another KSeF failure occurs during this 7-day period, also officially announced, a new 7-day deadline begins from the end of the new failure.

    The date of issuance in emergency mode is the actual date the document was issued, in accordance with Article 106e(1)(1) of the VAT Act, not the date of submission (if submitted within the 7-day deadline).

    Example. A KSeF failure occurred on January 8 and lasted until January 9. The taxpayer issued an invoice in emergency mode on January 9 and submitted it to KSeF on January 14, within the legal timeframe. The date of issuance is January 9.

    Offline mode (KSeF unavailability)

    Offline mode enables the issuance of structured invoices during temporary unavailability of the National e-Invoicing System (KSeF), e.g., due to scheduled maintenance. This ensures uninterrupted invoicing and operational continuity.

    An invoice issued in offline mode must be submitted to KSeF no later than 1 business day after the end of the system’s unavailability to receive a KSeF number.

    If a KSeF failure occurs during this 1-day period (officially announced), the invoice must be submitted within 7 business days after the end of the failure.

    The date of issuance is the actual date the document was issued, in accordance with Article 106e(1)(1) of the VAT Act, not the date of submission (if submitted within the legal deadline).

    Example. On January 12, a KSeF outage occurred due to maintenance. The taxpayer issued an invoice in offline mode on the same day and submitted it to KSeF on January 13, meeting the legal deadline. The date of issuance is January 12. 

    Total system failure

    A total system failure is an exceptional situation that may threaten the functioning of the state or its critical infrastructure. Procedures for such cases have been developed in response to Poland’s current geopolitical conditions (Article 106ng of the VAT Act).

    In the event of a total failure, offline mode means reverting to traditional methods of issuing sales invoices, outside the KSeF system. After the failure ends, there is no obligation to submit these invoices to KSeF.

    In the event of a total system failure, we recommend documenting the situation by taking a screenshot of the error message with a visible date and time, and—if possible—saving the log from the invoicing system. Next, the operational status of KSeF should be checked at https://ksef.mf.gov.pl or in official announcements from the Ministry of Finance. If the failure is confirmed on the KSeF side, it is advisable to retain a screenshot of the Ministry’s communication. The purpose of these actions is to document the date and cause of the system outage.

    Submission deadlines

    • Online mode – on the same day the invoice is issued.
    • Offline24 mode – immediately, but no later than the next business day after issuance.
    • Emergency mode – within 7 business days from the end of the KSeF failure.
    • Offline mode – within 1 business day from the end of KSeF unavailability.
    • Total system failure – no obligation to submit the invoice to KSeF after the failure ends.

    Penalties for failure to submit to KSeF on time

    If a structured invoice is issued but not submitted to KSeF within the required timeframe, the

    Head of the Tax Office may impose the following sanctions:

    • up to 100% of the VAT amount shown on the invoice issued outside KSeF.
    • or 18.70% of the invoice value, if the document does not include VAT.

    NOTE: NO FINANCIAL PENALTIES WILL BE APPLIED FOR KSEF-RELATED VIOLATIONS UNTIL DECEMBER 31, 2026.

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