KSeF in a physiotherapy practice in 2026 - what to know

Ms Agnieszka runs a sole-trader physiotherapy practice near Warsaw. Her physiotherapy services are VAT-exempt, so up to now she's issued patients plain receipts and businesses VAT-free invoices. When she heard the phrase "KSeF from 2026 for everyone", she started to wonder: does she, being VAT-exempt, even need to worry about this? And if so -- from when, and how?

This is one of the most common questions physiotherapists are asking in 2026. In this article, we explain what the Polish e-invoicing system (KSeF) is, who it covers and from when, how patient invoices are affected, and exactly what you need to do in your practice.

What KSeF is

KSeF (the National e-Invoice System) is the central, government-run system for issuing and receiving structured invoices, operated by the Ministry of Finance. A structured invoice is an XML file in a specified format that you submit to KSeF -- and only then is the invoice considered issued and delivered.

The system's purpose is to close VAT loopholes and fully digitise invoicing. In practice, for a business owner, this means the end of issuing invoices "outside the system" -- every B2B invoice goes through KSeF.

Rollout schedule -- who's covered and from when

Mandatory KSeF is being rolled out in stages. The key dates:

Deadline	Who it covers
1 February 2026	Taxpayers with sales above PLN 200 million (in 2024)
1 April 2026	All other taxpayers -- including those exempt from VAT
1 January 2027	Only the smallest taxpayers: those issuing invoices up to PLN 450, with sales up to PLN 10,000 (gross) per month

Watch out for a common misconception: the deferral to 2027 does not depend on VAT exemption. The only criterion is the scale of invoicing -- individual invoices up to PLN 450 and total invoiced sales of no more than PLN 10,000 gross per month. For a typical physiotherapy practice this means that a VAT-exempt taxpayer whose sales exceed PLN 10,000 a month joins mandatory KSeF from 1 April 2026 -- together with everyone else. The 2027 deferral applies only to genuinely small-scale operations.

Physiotherapy and the VAT exemption

Healthcare services aimed at prevention, preservation, rescue, restoration and improvement of health, provided by a physiotherapist, are exempt from VAT under Article 43(1)(19) of the VAT Act. This is a subject-matter exemption -- it depends on the nature of the service, not on turnover.

Consequences for KSeF:

• VAT exemption does not defer the KSeF obligation. If your sales exceed PLN 10,000 gross per month, you're required to issue invoices in KSeF from 1 April 2026, like other taxpayers.
• Only if you stay within the limit (invoices up to PLN 450, sales up to PLN 10,000 a month) do you benefit from the deferral to 1 January 2027.
• Regardless of when you must issue invoices, you'll be receiving invoices via KSeF from April 2026 -- once your suppliers (e.g. your landlord, an equipment supplier) start issuing invoices in KSeF, they'll land in your account in the system.

Patient invoices -- what changes

This is the most common misunderstanding. Invoices for consumers (patients who are private individuals not running a business) generally don't need to go through KSeF. A consumer invoice can be issued outside the system, and the patient receives it as before -- on paper or as a PDF.

In practice, in a physiotherapy practice:

• A private patient (an individual) -- a receipt or consumer invoice, outside KSeF.
• A patient invoicing as a business / an invoice made out to a company -- this is a B2B relationship, ultimately handled through KSeF (from your applicable deadline).
• Suppliers (rent, equipment, accounting) -- you'll receive purchase invoices via KSeF.

The patient's right to an invoice, and your obligation to issue one on request, remain unchanged.

What exactly you need to do in your practice

1. Establish your applicable deadline -- work out your monthly invoiced sales. Above PLN 10,000 gross a month, you join from 1 April 2026; only at a smaller scale (and with invoices up to PLN 450) does the deferral to 2027 apply.
2. Set up access to KSeF -- authentication via certificate, qualified signature, trusted profile or token. Even exempt taxpayers will be receiving invoices.
3. Check your invoicing / accounting software -- ask your accountant or software provider whether it integrates with KSeF.
4. Grant permissions -- if your accountant invoices on your behalf, you need to grant them permissions in KSeF.
5. Prepare a procedure -- how you issue an invoice to a patient invoicing as a business, versus a private patient.
6. Get your data right -- B2B invoices must include the buyer's correct tax ID (NIP); private patients' data without a NIP goes through as consumer invoices.

[SP] Sole-Practice example: Ms Agnieszka is VAT-exempt, but her practice generates around PLN 18,000 in revenue a month -- so she exceeds the PLN 10,000 limit and must issue invoices in KSeF from 1 April 2026, like any other taxpayer. On top of that, from the same date her landlord (an active VAT payer) starts sending her invoices through KSeF, so she needs access to the system both to issue and to receive invoices.

[GR] Group-Practice example: The company running the practice has mixed sales -- physiotherapy services (exempt) and commercial training (taxable). At a group practice's turnover, the PLN 10,000-a-month limit is exceeded by a wide margin, so the KSeF obligation from 1 April 2026 is certain -- it's worth implementing the system ahead of time to avoid chaos at the start.

Invoice vs receipt -- what a physiotherapist issues

In a VAT-exempt practice, the question often comes up of whether to issue a "receipt" or an "invoice". Following changes to the regulations, a VAT-exempt taxpayer generally documents sales with an invoice (without VAT) rather than a classic receipt, although a private patient doesn't always have to receive one unless they request it. In practice:

• A private patient -- receives proof of payment; you issue an invoice on request, outside KSeF.
• A patient invoicing as a business -- a B2B invoice, ultimately via KSeF (from your applicable deadline).
• Income records -- kept in line with your form of taxation and record-keeping requirements.

It's worth agreeing a single, consistent standard with your accountant so the two workflows don't get mixed up.

Penalties and risks

Sanctions are provided for issuing an invoice outside KSeF once the obligation already applies to you. In addition, an invoice issued outside the system, when it should have been structured, may be challenged as not properly issued. That's why it's crucial to establish the correct start date for your practice -- getting it wrong "a year too late" is just as costly as going in "a year too early, in chaos".

Frequently asked questions

I'm a VAT-exempt physiotherapist -- does KSeF apply to me?

Yes -- VAT exemption doesn't defer the obligation. Taxpayers exempt from VAT join mandatory KSeF from 1 April 2026, together with everyone else. The deferral to 1 January 2027 covers only the smallest taxpayers: those issuing invoices up to PLN 450, with sales up to PLN 10,000 gross a month. If your practice exceeds that limit, your obligation starts in April 2026.

Do I have to issue invoices to patients via KSeF?

Invoices for patients who are consumers (individuals not running a business) generally don't go through KSeF -- the patient receives them as before. B2B invoices go through KSeF, i.e. for example when a patient asks for an invoice made out to their company.

How do I get access to KSeF?

You authenticate using a KSeF certificate, a qualified electronic signature, a trusted profile, or a token generated in the system. If an accounting office invoices on your behalf, you grant them permission to act on your behalf.

What if I have mixed sales -- exempt and taxable?

It makes no difference to your KSeF start date -- the deadline depends on the scale of invoicing, not your VAT status. Mixed sales usually mean higher turnover, so it's all the more likely you exceed the PLN 10,000-a-month limit and your obligation starts on 1 April 2026. Discuss with your accountant how to account for VAT on the taxable part.

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