This article is for JDG owners who are not registered as VAT payers (exemption for turnover up to 240 000 zł a year), and for those who pay ryczałt. In short: exemption from VAT does not exempt you from KSeF. Invoices must be received through KSeF from 1 February 2026 and issued from 1 April 2026, and if your invoices for firms total less than 10 000 zł a month, until the end of 2026 they can be issued the old way.
Ryczałt has nothing to do with it, VAT is what matters
KSeF is a rule on invoices from the VAT act. The form of income tax does not affect it: ryczałt, the tax scale or liniowy, the obligations are the same. What matters is something else: whom you sell to and for what amount you issue invoices. A ryczałtowiec (ryczałt payer) who is a czynny podatnik VAT (active VAT payer) works with KSeF in the same way as any VAT-registered firm.
Those exempt from VAT, whether by turnover or by type of activity, are not excluded from KSeF. The Ministry of Finance states it plainly: every taxpayer, czynny or zwolniony (exempt), who has an obligation to issue an invoice issues it in KSeF.
When a VAT-exempt business issues an invoice at all
An exempt taxpayer is not, as such, obliged to issue an invoice. The obligation arises if the buyer asks for one within 3 months from the end of the month in which you sold the goods or provided the service. Business clients almost always ask, so in practice everyone has invoices for firms.
You cannot get around KSeF by writing a rachunek (bill) instead of an invoice. In a clarification of January 2026 the Ministry of Finance stated: if there is an obligation to issue an invoice, the exempt taxpayer issues precisely an invoice.
Dates for a JDG without VAT
- From 1 February 2026: all firms, including those exempt from VAT, receive invoices through KSeF. An invoice is treated as received when it has been assigned a KSeF number, even if you have not opened it.
- From 1 April 2026: everyone except the smallest businesses must issue invoices in KSeF.
- Until 31 December 2026: invoices can be issued outside KSeF (on paper or as a PDF) if the total of such invoices for the month is no more than 10 000 zł including VAT. Until the same date, invoices from a cash register remain outside KSeF, including a paragon z NIP (receipt with the buyer’s NIP) up to 450 zł.
- From 1 January 2027: KSeF is mandatory also for those who used the 10 000 zł limit.
These are the same dates as in our article KSeF in 2026 and 2027.
The 10 000 zł monthly limit: how to count it
- The amount including VAT is counted. For a VAT-exempt business this is simply the invoice amount.
- The limit includes only invoices that would have to go through KSeF anyway, that is invoices for firms and business owners.
- It does not include invoices for private individuals (konsumentów) or paragony fiskalne (fiscal receipts) up to 450 zł, which count as simplified invoices.
- The month is determined by the date the invoice is issued, not by the date of sale.
- The invoice on which the limit is exceeded is already issued in KSeF, as are all subsequent ones. You cannot go back to the old invoices in a month with lower turnover.
Worked example
A hypothetical example, not a client case. A JDG on ryczałt without VAT provides services to firms and private individuals.
- March 2026. Invoices for firms of 4 000 zł and 3 500 zł, invoices for private individuals of 2 800 zł. Only 7 500 zł counts towards the limit, so all invoices can be issued outside KSeF.
- April 2026. Firms are invoiced 6 000 zł on 8 April and 5 000 zł on 22 April. After the second invoice the total is 11 000 zł and the limit is exceeded, so the invoice of 22 April must already be issued in KSeF.
- May 2026 onwards. All invoices for firms only in KSeF, even if in some month they total 2 000 zł.
If such a business owner’s sales for the year approach 240 000 zł, the next step will be VAT registration. How to count this threshold is explained in the article the VAT exemption limit of 240 000 zł.
Invoices for private individuals and the cash register
Invoices for konsumentów (B2C) do not have to be issued in KSeF, either before 1 February 2026 or after. They can also be issued in KSeF, in which case the buyer receives a PDF or paper version with a QR code. KSeF is also voluntary for an invoice to a business owner who buys from you for personal purposes.
Sales through a cash register (kasa rejestrująca) are still documented with receipts. Invoices issued by the cash register, including a paragon z NIP up to 450 zł, may remain outside KSeF until 31 December 2026. From 2027 this transitional period ends.
Penalties: there are none in 2026
Under the current law, penalties for breaches in KSeF apply from 1 January 2027: up to 100% of the VAT amount on the invoice, and for an invoice without VAT up to 18.7% of its amount. On 16 September 2026 the Ministry of Finance announced that it wants to move the start of penalties to 1 January 2028. On the check date this is a draft; the law has not been adopted. The obligation itself to issue invoices in KSeF does not change because of the postponement.
From 1 January 2027, a bank transfer for an invoice from KSeF must include its KSeF number. This rule applies to payments between czynni podatnicy VAT. If one of the parties is exempt from VAT, it does not apply.
What to prepare now
- Decide how you will log in to KSeF: Profil Zaufany, mObywatel, a bank or a qualified signature.
- Look at the incoming invoices in KSeF: VAT-registered suppliers are already sending them there.
- Grant the bureau the permission to access invoices. The procedure is described in the article how to give your accountant access to KSeF.
- Choose where you will issue invoices: in the free Aplikacja Podatnika KSeF or in software connected to KSeF.
- If you use the 10 000 zł limit, count your invoices for firms month by month so that you notice the moment it is exceeded.
- Issue your first invoices in KSeF while still in 2026, while there are no penalties.
Frequently asked questions
I am on ryczałt and without VAT. Do I need KSeF at all?
Yes, if you issue invoices to firms or receive invoices from VAT-registered suppliers. Receiving through KSeF is required already now. Issuing too, if your invoices for firms total more than 10 000 zł a month. From 2027 there is no limit.
I work only with private individuals. What changes?
Almost nothing: invoices for private individuals are not mandatory in KSeF, and cash register receipts remain receipts. But invoices issued to your NIP arrive through KSeF.
In one month I exceeded 10 000 zł. Can I go back to PDF the next month?
No. Starting from the invoice on which the limit was exceeded, all invoices for firms are issued only in KSeF.
A business client asks for an invoice, but I am exempt from VAT. Can I give a rachunek?
According to the Ministry of Finance, no: if the buyer asks for an invoice in time, the exempt taxpayer issues an invoice, and from the date of their obligation issues it in KSeF.
We keep the books of a JDG on ryczałt and without VAT, collect incoming invoices from KSeF and track the limits against your sales. More on the page accounting for a JDG. The cost of bookkeeping is shown by the calculator on this page.
Checked as of 5 October 2026. This is general information, not tax advice.
Sources: KSeF: do 10 000 zł miesięcznie, KSeF: konsumenci i osoby fizyczne, Pytania i odpowiedzi KSeF 2.0, MF: odroczenie kar do końca 2027 r.
