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The implementation of the National e-Invoicing System (KSeF) is not only a change in accounting but also a significant disruption to how entire business processes and IT systems operate. Although the system is ultimately intended to improve the circulation of documents, it also imposes a specific technical framework on taxpayers. In practice, not only the content of the invoice may pose a challenge, but also its size and the frequency of communication between the company and KSeF. Exorigo-Upos experts discuss key technical nuances that can have a real impact on enterprise operations.
1 MB – the limit that must not be exceeded
According to the guidelines of the Ministry of Finance, a single XML document sent to the system cannot “weigh” more than 1 Mb. Although this limit is difficult to exceed for a standard invoice, the situation changes for collective invoices, which can include thousands of items.
– Most entrepreneurs do not have to worry about the file size limit, but companies from the retail, logistics, or energy sectors, issuing invoices for thousands of services or products on one document, must verify in their processes whether they will not exceed the limits imposed by KSeF – points out Michał Sosnowski, Business Development Director at Exorigo-Upos.
No more traditional attachments
The biggest operational change is the complete resignation from PDF or JPG attachments. KSeF accepts only structured text data, which means that specifications, acceptance protocols, or cost estimates cannot be “pinned” to an e-invoice. Additional information must be included in the text fields provided for this purpose (e.g. AdditionalDescription) or provided to the counterparty through a separate channel.
An alternative is to include links to external data repositories in the invoice body. In special cases, after obtaining the consent of the Tax Office for the use of the structured attachment (by sending the ZGL_ZAL form in e-US), additional information can be provided to the counterparty in the optional Attachment node. An e-invoice containing a structured attachment allows you to send a larger XML file – up to 3 Mb.
– It should be remembered that even when using the “Attachment” node, there is still a limit of 10 thousand items on one invoice – this is the number of lines (FaRow) allowed by the FA(3) scheme. Although increasing the XML file size limit would theoretically allow more items, in practice, the line limit is more easily met than the 3 Mb limit. This is a problem that has repeatedly been flagged to the Ministry of Finance. Both constraints are impractical and often require costly changes to business processes, even when the invoice is only the final stage of a complex chain of events. As a result, these are areas in which KSeF, instead of helping, makes it really difficult for companies to operate, notes Michał Sosnowski.
Batch sessions and bulk limits
For entities generating large volumes of documents, KSeF provides batch sessions. Restrictions apply here as well – the total size of a compressed package of documents (ZIP) cannot exceed 100 MB.
– Exceeding these parameters results in the rejection of the entire session by the ministry’s gate, which in practice may mean failure to comply with the obligation to issue an invoice on time, adds Paweł Pustelnik, responsible for the SmartKSeF system at Exorigo-Upos.
In retail, where milliseconds count in customer service at checkout, it is crucial to use KSeF’s interactive invoicing mode. It allows you to quickly send an invoice to the system and obtain a KSeF number almost immediately.
– We are positively surprised by the pace of issuing invoices by KSeF, which allows for a quasi-online process, but here we are also subject to imposed limits – the maximum number of invoices that can be issued per second, minute, and hour. At the current stage, even on ordinary trading days, nationwide retailers issue many more invoices than the limits allow. We support our clients in obtaining Tax Office approval to increase limits to improve retail customer service. Importantly, the first users of SmartKSeF have already received such consent, Paweł Pustelnik points out.
Optimization is key
Experts emphasize that the key to a smooth transition to KSeF is the audit of data sent in XML files. A good reference point is historical data, which helps you assess whether there is a real risk of blocking or suspending invoice issuance in KSeF and, to what extent, this is an incidental event.
The implementation of the National e-Invoicing System is not only a formal change, but a real operational challenge for companies. In addition to filling in invoices correctly, entrepreneurs must take into account technical limits – both in terms of the number of items and the size of files – and choose the optimal mode of communication with the system. Being aware of these limitations and preparing processes in advance allows you to take full advantage of the opportunities offered by the new e-invoice system.
