XML or EDI invoices: when KSeF verification codes may be separate

If a structured data format prevents placing a verification code directly on the invoice, the appropriate link or code may be supplied separately — together with the invoice and the correct label. This does not remove the requirement to supply the code.

The condition: the format prevents marking

The Ministry handbook discusses EDI, where businesses exchange documents in an agreed format, such as XML, without necessarily producing a visual version. The actual format limitation matters. Inconvenient PDF editing alone does not justify this alternative. Source: handbook §5.4.4.

With the invoice and the correct label

Separate links or graphical codes may be attached. They must be the appropriate invoice verification codes, not arbitrary links to a seller's portal. Preserve the situation-dependent labels: KSeF number, OFFLINE or CERTYFIKAT.

For an ONLINE invoice used or supplied outside KSeF under the described rules, KOD I carries its KSeF number. Before an OFFLINE invoice is sent to KSeF, in the outside-system supply cases described in §5.4.1–2, KOD I is labelled OFFLINE and KOD II CERTYFIKAT. Do not choose the label solely from the file extension.

FAQ

Does the exception apply to every PDF?

No. The condition is a structured data format that prevents directly placing the code or link on the invoice.

Is a separate link supplied with the invoice?

Yes. This alternative supplies the marking separately with the invoice; it does not leave the recipient without the proper code or link.

Can OFFLINE or CERTYFIKAT be omitted?

No, where that label is required for the situation. Separate delivery does not remove the appropriate label requirement.

Source and limits

KSeF 2.0 handbook, part II, §5.4.1–4, August edition, checked 7 October 2026; cover legal position: 1 February 2026. Polish-system scope; no code-generation instructions, later-submission deadlines or complete offline guide.