The target definition of a structured invoice has been published

On the websites of the Central Repository of Model Electronic Documents (pattern number 2023/06/29/12648) and the Ministry of Finance, the target definition of a structured invoice was announced, in the form of the so-called Schema FA, version 2 of which was long awaited by taxpayers.

According to the Ministry of Finance (MF) announcement, taxpayers will first have the opportunity to familiarize themselves with the new e-invoice structure in the KSeF test environment. From July 2023, this environment will support the new FA(2) logical structure. At the same time, the currently used FA(1) structure will continue to be available on the test KSeF until August 2023 to enable a smooth transition between the two significantly different structures.

• The Ministry of Finance plans to make the new version of the FA(2) schema available on the KSeF production environment on September 1, 2023.
• The new version of FA(2) will remain unchanged until the end of 2024, which means that changes will be frozen in the production environment for almost a year and a half.
• It is not excluded that the Ministry of Finance may introduce corrections to errors reported, e.g., from tests of the new FA(2) structure.
• Compared to the last working version of the FA(2) scheme, the Ministry of Finance introduced some differences, such as shortening the KSeF invoice identifier format to 35 characters:
  • invoice according to scheme FA(1) 5252535950-20230706-22A8B2-C03BD0-50
  • invoice according to scheme FA(2) 5252535950-20230706-CF6E4C273346-70
• The markings of local government units have also been changed.
• A change was published regarding the need to provide both the invoice number and the KSeF ID for advance invoices issued in the KSeF.
• Additionally, a special tag, “advance invoice issued outside KSeF,” was introduced.
• According to the announcement of the Ministry of Finance, the legislative process related to the implementation of the amendment to the VAT Act introducing a mandatory e-invoice from July 1, 2024, which is currently under analysis in the Senate, should be completed by the end of July.
• After the act is passed, the Ministry of Finance will consult the regulations specifying the use of structured invoices, such as the regulation on the use of KSEF, the law on exclusions from the KSEF, the amendment to the rule on issuing invoices and the amendment to the government on JPK_VAT.
• The above regulations are expected to enter force in the fourth quarter of 2023.

The Ministry of Finance focuses on the reporting obligations of taxpayers, in particular JPK_FA and JPK_VAT, and the introduction of KSeF aims to simplify tax settlements further and reporting.

To effectively convey information, the Ministry of Finance is planning an intensive information campaign, which will include meetings, webinars, and activities on social media. The campaign aims to educate and increase awareness of the new regulations related to electronic invoices.

During the press meeting, it was announced that Germany and Romania received a draft derogation decision regarding the mandatory use of e-invoices, which confirms the correctness of Poland’s actions in the digitalization of trade in the European Union. Obtaining a derogation allows these countries to use a mandatory e-invoice, contributing to harmonizing digital processes within the EU.

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