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On 8 May, the Ministry of Finance published a draft of the new logical structure of the FA(3) e-invoice, which will become a binding standard from 2026. The latest version of the document responds to business needs and the development of the KSeF system—it introduces several modifications aimed at increasing flexibility, more precise transaction identification, and better adaptation to complex business scenarios.
What exactly is changing? Here are the main objectives of the FA(3) project:
Structured Attachments
The most significant novelty is the possibility of attaching attachments to VAT invoices in the KSeF. This solution paves the way for registering additional structured data as a universal, multidimensional table – e.g. advanced product specifications or project settlements. In the published examples, the Ministry of Finance presented several illustrative e-invoices with the Zalacznik node filled in.
Other changes include technical issues and less common scenarios important for selected user groups. It is worth appreciating that the Ministry of Finance has considered many postulates submitted during public consultations, including those submitted by Exorigo-Upos experts.
Base Changes
The FA(3) draft introduces changes at the technical level—the schema code has been modified to “FA(3),” and a new TDataU data type has been defined (supporting the range of 1990–2050). The bank account number (TNrRB) and tax identifier (NrID) formats have also been improved, allowing special characters and extending the length of the fields.
Expansion of dictionaries and data types
Dictionaries and data types have been significantly expanded. A new role of “Pracownik” (value 11) in TRolaPodmiotu3 in the identification of employee expenses has been introduced, including the 0% VAT rate, which has been differentiated into three variants: domestic (0 KR), ICS (0 ICS) and export (0 EX). For non-taxable transactions, the dictionary has been expanded to: “np I” and “np II”. In addition, a new data type, TZnakowy2 (max 256 characters), has been added in the invoice attachment.
Facilitation of subject data
Further changes concern entity identification. The obligation to provide the address for Podmiot3 has been abolished, tags have been added for subordinate units of local government units and members of the VAT group, and the rules for correcting buyer data for Podmiot2k have been clarified.
Payments and deadlines
In the field of payments, the method of presenting deadlines has been simplified and clarified – now it is possible to specify the unit of time, its type and initial event. In addition, the partial payment marker (ZnacznikZaplatyCzesciowej) has gained a new “2” value denoting the payment in full. It is also possible to indicate the form of payment for each tranche separately, and for electronic transactions, the LinkDoPłatności and IPKSeF fields have been added.
Data on goods and services
The maximum length of the item/service name field (P_7 and P_7Z) has also been changed to 512 characters, and a limit of 50,000 items in the corrected invoice data has been introduced. The range of dates that can be used in contracts has also been extended to cover the period from 1990 onwards.
Not everything has been taken into account
Although some postulates submitted during the consultations have been considered, some critical needs remain unresolved, such as increasing the maximum file size of an e-invoice. For many larger enterprises, this is still a barrier to full implementation of the KSeF, especially with more complex documents.
What’s next?
The FA(3) project is a step towards a modern, more flexible and functional e-invoicing system. Although the final version of the schema and a detailed schedule for its implementation will be announced in the coming months, companies can already start preparing for the final integration.
At the same time, we reassure you – if you do not plan to use the new capabilities offered by FA(3), you can continue to use the current SmartKSeF API without any changes.
Exorigo-Upos customers can feel safe—SmartKSeF will ensure compliance with the KSeF system’s requirements, regardless of the pace of implementation of new functions. Changes will be possible at any time convenient for you.
Want to learn more about how to prepare for FA(3)? Contact our expert – Michal.Sosnowski@exorigo-upos.pl.
