Summary
- Challenges related to KSeF – an efficient work model
- Challenges related to e‑Delivery – ongoing inbox monitoring
- Challenges related to the e‑Tax Office and PUE ZUS – more and more tax matters online
- How to obtain access to public administration portals?
- Can foreigners gain access to Polish public administration portals?
- What’s next? The European perspective
Challenges related to KSeF – an efficient work model
In February 2026, during the first weeks of the National e‑Invoicing System (KSeF) rollout for so‑called “large taxpayers,” the system’s performance was tested under real load conditions. As it turned out, it did not fully pass this test. In addition to typical implementation problems, temporary disruptions occurred in the KSeF Taxpayer Application and in login channels (login.gov.pl and the Trusted Profile – “Profil Zaufany”), which the Ministry of Finance communicated in technical notices. External monitoring tools also confirmed these issues. This is particularly important in the context of the upcoming expansion of the obligation. As of 1 April 2026, KSeF will cover most businesses (excluding the smallest entities, which will join in January 2027). This means further system load growth, and companies should prepare for it in advance.
One of the key steps on the company side is appointing a so‑called super‑administrator responsible for granting system access.
Important
This person is designated in the ZAW‑FA form, signed by an individual authorised to represent the company according to data in KRS or CEIDG (in companies, typically a management board member).
The form may be submitted on paper, electronically (qualified signature), or through the e‑Tax Office. Only after successful submission can additional accesses be assigned. An alternative is using a qualified electronic seal containing the company’s NIP. In this case, the system identifies the entity directly and allows the first authentication without submitting the ZAW‑FA form. For many companies, this is organisationally simpler, especially when the management board is multi‑member or located outside Poland.
At the same time, it is necessary to design an efficient work model – including integrating accounting systems with KSeF, ensuring continuity of access, preparing procedures in case of system failures, and clearly defining internal responsibilities. KSeF is therefore not just a technological rollout but a transformation of the organisation of financial‑accounting processes in the company.
Challenges related to e‑Delivery – ongoing inbox monitoring
KSeF is not the only system requiring active management. e‑Delivery (the National Electronic Delivery System) is gaining increasing importance. It serves as the electronic equivalent of a registered letter for communication with public administration. According to the statutory schedule, in 2025 and 2026 additional public entities transitioned to this communication channel, and companies registered in KRS have been required to maintain an active e‑Delivery address since 2025.
Importantly, a message sent via e‑Delivery has the same legal effect as a registered letter with acknowledgment of receipt. The so‑called “fiction of delivery” applies. This means that a document is considered delivered 14 days after it has arrived in the recipient’s electronic inbox, even if it has not been read. This creates the need for constant inbox monitoring and clearly assigned responsibility for receiving correspondence.
Challenges related to the e‑Tax Office and PUE ZUS – more and more tax matters online
An increasing number of interactions with tax authorities now occur via the e‑Tax Office (e‑US). The system allows: submitting declarations, applying for tax refunds, obtaining certificates, tracking tax settlements, paying taxes and fines, and receiving correspondence from the National Tax Administration.
Additionally, e‑US makes it possible to schedule in‑person appointments at the tax office. It is also through e‑US that taxpayers can obtain their telePIN for contacting the National Tax Administration helpline, which is required for receiving individual tax information by phone. Therefore, many procedures that previously required visiting an office can now be handled online, without leaving the desk or going to the post office.
A similar direction toward increased digitalisation can be observed in the activities of the Social Insurance Institution (ZUS). The Electronic Services Platform (PUE ZUS) enables the handling of insurance notifications, correspondence, and contribution settlements, and for many companies it has become a daily HR and payroll tool.
How to obtain access to public administration portals?
It is important to note that electronic public administration services are based on verifying the identity of a specific person authorised to act on behalf of the company. The most commonly used methods are a qualified signature, Trusted Profile, online banking, e‑ID card, or the mObywatel application.
Important
An exception is the qualified electronic seal, which authenticates the company in KSeF without identifying an individual. While convenient, it comes with extra costs, the need for strict access control, and the risk associated with sharing a certificate.
Regardless of the chosen method, it is essential to maintain a balance between operational efficiency and security. The permission‑granting system must ensure access only for authorised individuals, while also considering substitution – meaning that the absence of one employee should not disrupt the company’s operations or timely fulfilment of tax, legal, and administrative obligations.
Can foreigners gain access to Polish public administration portals?
Access to Polish administrative portals is not territorially restricted, so people outside Poland may use them if they have the required identification methods. This is especially relevant for companies in Poland with foreign capital. EU citizens may use their national electronic identification (eID) if their system is integrated with the EU eIDAS node. In practice, however, not all Polish systems currently support the full scope of such logins.
In the case of KSeF, authentication with an eIDAS‑compliant qualified electronic signature is also possible, even if the certificate does not contain a NIP or PESEL number. The condition is submitting to KAS the “certificate fingerprint,” i.e., the SHA‑256 identifier associated with the signature certificate.
Many foreign nationals also obtain a PESEL number and a Trusted Profile. This requires prior formal arrangements, and even after gaining access, a practical challenge remains: not all public administration systems offer full language versions other than Polish.
What’s next? The European perspective
In the coming years, electronic public services will be gradually expanded at the European level. The eIDAS 2.0 Regulation requires EU member states to implement the European Digital Identity Wallet, intended to simplify identification in public and private services across the EU.Electronic banking shows that such solutions are possible. KYC/AML identification requirements facilitate system integration and the simplification of cross‑border identity verification.
However, in the area of taxes and public administration more broadly, full integration will be implemented gradually, because beyond identity verification, it also requires linking tax numbers, powers of attorney, and authorisations derived from national registers. This requires time, system adjustments, cooperation, and coordination between countries. Therefore, the process will move forward slowly, but its direction is already clearly defined.
The key aspect of digital obligations is no longer simply having access to systems, but ensuring their real functionality in day‑to‑day operations. Companies should clearly assign responsibilities, ensure substitution mechanisms, and maintain efficient processes and system integrations to minimise the risk of delays.
Organisations that treat digitalisation as a continuous management strategy—not a one‑time implementation—will gain an advantage.
It is therefore worth conducting an audit of obligations, verifying system readiness, organising role structures, and continuously monitoring operational risks.
You can read more about the challenges associated with the digitization of accounting in the series of articles “New digital obligations for businesses” on the Grant Thornton website:
- New digital obligations for businesses: National e-Invoice System (KSeF)
- New digital obligations for businesses: The National e Invoicing System (KSeF)
- New digital obligations for businesses: JPK CIT
- New digital obligations for businesses: the biggest challenges related to digital accounting
The biggest challenges related to digital accounting – frequently asked questions
What is the main challenge of accounting digitalisation?
It requires using multiple public administration systems simultaneously, which creates technological, organisational, security, and access‑management challenges.
How to gain access to public administration portals?
Through a qualified signature, Trusted Profile, online banking, e‑ID, or the mObywatel app. An exception is the qualified electronic seal, which identifies the company in KSeF without identifying a person.
Can foreigners use Polish administrative systems?
Yes, if they have the appropriate identification methods, e.g. eID compliant with eIDAS, a qualified signature, or a PESEL and Trusted Profile. However, not all systems offer language versions other than Polish.