KSeF: reporting permissions again after extending or replacing a signature

When must permissions linked to a signature fingerprint be reported again?

In its answer to question 19 in the KSeF FAQ, the Ministry of Finance identifies two cases in which permissions linked to a signature’s “fingerprint” must be reported again:

• Extending the signature’s validity — permissions linked to its fingerprint must be reported again.
• Obtaining a new signature for the same person — permissions linked to its fingerprint must also be reported again.

Important scope limitation

The key condition is that the permissions are linked to the signature’s fingerprint. The Ministry’s answer should not be extended to all KSeF permissions or all authentication methods.

This guide does not cover changing a token’s scope, KSeF certificates of types 1 and 2, or granting an accountant access in general. It should not be treated as instructions on those topics.

Optional organizational checklist

To organize your own checks, you can establish:

• whether the signature’s validity has been extended or a new signature has been obtained for the same person;
• whether the permissions under consideration are linked to that signature’s fingerprint.

This is an organizational suggestion, not an additional official requirement. It does not replace reporting the permissions again when the conditions identified by the Ministry of Finance are met.

Limits of this guide

This article is limited to identifying when the specified permissions must be reported again. It does not provide a reporting procedure, forms, deadlines or interface steps. It does not determine whether permissions are transferred or expire automatically, and it does not guarantee that access will be restored.

Source: Ministry of Finance — Frequently asked questions, question 19.