KSeF for Foreign Founders in 2026: How a New Polish Company Gets Access

KSeF is already part of operating a Polish business

Mandatory structured e-invoicing through KSeF was introduced in stages in 2026. For most taxpayers, the obligation to issue invoices through KSeF started on 1 April 2026. The smallest taxpayers can remain outside mandatory issuing until the end of 2026 only if monthly sales documented by invoices do not exceed PLN 10,000 gross. Receiving KSeF invoices has been mandatory since 1 February 2026 for taxpayers within the system, subject to statutory exceptions.

For a newly registered foreign-owned Sp. z o.o., access should therefore be organised at the same time as accounting, the bank account and VAT registrations.

A JDG and a Sp. z o.o. enter KSeF differently

An individual entrepreneur with a Polish NIP receives owner-level KSeF rights automatically. A company such as a Sp. z o.o. is different because the system needs a way to authenticate the legal entity or appoint a person who can act for it.

If the company has a qualified electronic seal containing its NIP, it can authenticate directly. If it does not, the usual route is a ZAW-FA notification appointing a natural person to use KSeF for the company.

The person on ZAW-FA does not have to be the CEO

Official KSeF guidance states that the person designated on ZAW-FA can be any natural person chosen by the company; they do not have to be the person who represents the company in the KRS. This is useful for foreign founders because the company can appoint a trusted director, employee or other person who will then grant further permissions electronically.

Only one natural person is designated through the initial ZAW-FA. That person can then give additional KSeF permissions to other people or entities, such as the accounting office.

What if the foreign director has no Polish PESEL?

KSeF has procedures for qualified electronic signatures that do not contain a Polish NIP or PESEL. In those cases the system can use unique data linked to the qualified certificate - commonly described as the signature fingerprint - after the relevant data are notified. This matters for foreign directors using a qualified signature issued outside Poland.

The practical route depends on the signature, the company's electronic seal and the identifiers held by the person who will administer KSeF. It is better to decide this before the first invoice is due.

Your accountant does not automatically see the company’s invoices

Signing an accounting-services agreement does not automatically give the accounting office access to the client's KSeF context. The company must grant the required permissions. The accounting office then authenticates separately in the context of each client's NIP, although commercial software can automate parts of this process using KSeF certificates or other permitted authentication methods.

2026 is still a transition year

Special monetary penalties for failures connected specifically with mandatory KSeF are scheduled to apply from 1 January 2027. That does not remove the invoicing obligation in 2026; it simply means the first year is intended to allow businesses to adapt their systems and permissions before the sanctions regime begins.

How Neoplus can help

Neoplus can register the company, organise its accounting and help establish the KSeF permission chain so that invoices can be issued and received without the foreign founder having to manage every technical step personally.