Poland's National E-Invoicing System (KSeF): Key Updates and the New FA(3) Structure 

Poland is undergoing important changes in its e-invoicing framework, with significant updates to the National e-Invoicing System (KSeF). Businesses operating in Poland or dealing with Polish VAT are keeping a close watch as the Ministry of Finance prepares to introduce a new logical structure for the e-invoice, FA(3). Here’s what you need to know.

New FA(3) structure: consultation and business input

The Ministry of Finance will release the FA(3) e-invoice structure for public consultation in autumn 2024. This follows feedback received during earlier public consultations held in February and March 2024. The decision to modify the current FA(2) structure was influenced by the substantial feedback from businesses, underscoring the government’s intent to refine the system based on user experience and practical challenges. 

Businesses that have adapted their systems to the FA(2) structure will need to adjust once again for the upcoming FA(3). While change can often be seen as burdensome, the Ministry has indicated that these updates are designed to enhance the invoicing process and provide taxpayer-friendly improvements.

Key changes in the FA(3) structure

The new FA(3) structure will introduce several enhancements aimed at making invoicing more efficient and clear for businesses. Among the most notable updates are: 

• Presentation of the payment deadline: Clearer invoicing terms will aid businesses in managing cash flow and ensuring timely payments. 
• New ‘employee’ role in the Entity3 element: This addition recognizes a more complex organizational structure, supporting greater flexibility for invoice approvals and roles within an entity. 
• Increased character limit in the P_7 field: The name of the product or service field will allow more characters, making it easier to provide detailed descriptions without having to truncate crucial information. 
• Solutions for local government units and VAT groups: Specific adaptations to support more complex accounting structures typical of public sector organizations and groups operating under VAT regulations. 
  
  

These adjustments signal that the FA(3) structure is more comprehensive, making it better aligned with the needs of a diverse range of taxpayers, from small businesses to large enterprises and public sector entities. 

Legislative updates and second stage of legislation

While the FA(3) structure is in development, the Ministry of Finance is concurrently working on the second stage of legislation. Once this stage is complete, work on the implementation acts will resume, ensuring that the legal framework is robust enough to support the mandatory use of KSeF. 

As part of this process, the regulation of the Ministry of Finance from December 27, 2021 (Journal of Laws of 2021, item 2481, as amended), governing the use of KSeF, will be repealed. New regulations will be introduced, and while they will retain some of the previous provisions, they will also cover new elements that reflect the system's evolving scope, including: 

• QR codes: These will streamline invoice verification and processing.  
• Two-stage access to invoices: Improving security and control for businesses. 
• Internal certificates: Enhancing authentication and integration measures. 

KSeF architecture overhaul and no changes to KSeF numbering obligations

Following the results of an IT audit, the Ministry has also decided to rebuild the KSeF architecture from scratch. This will lead to a more stable and secure platform, but the Ministry has assured businesses that the reconstruction won’t significantly impact the integration work that has already been completed. This is good news for those who have invested in aligning their systems with KSeF requirements. 

Additionally, despite various rumors, the Ministry has confirmed that the obligation to provide the KSeF number when making payments for structured invoices will not be abolished. However, this requirement will only apply to payments starting from August 1, 2026.

Planned activities and system enhancements

To ensure smoother integration and usability of the KSeF system, the Ministry has outlined several initiatives for the near future, including: 

• Alignment of test, pre-production, and production environments: Aiming to provide a more stable environment for developers and integrators to work within. 
• Implementation of invoice attachments: This long-awaited feature will enable businesses to submit supporting documents along with their e-invoices. 
• Ongoing updates to the FA structure: Continuous improvements will ensure the system remains relevant and responsive to business needs. 

What should businesses do next?

With the upcoming changes, it’s essential for businesses to stay informed and prepared. Here are a few action points:

• Monitor the upcoming public consultation: Businesses should take advantage of this opportunity to provide feedback on the FA(3) structure, as this input has already proven to influence changes. 
• Prepare for FA(3) adaptation: Software providers and businesses using invoicing tools will need to ensure their systems are updated to accommodate the new structure once finalized. 
• Keep an eye on legislative developments: Understanding the second stage of legislation and its impacts on the mandatory use of KSeF will help businesses stay compliant. 

The evolution of Poland’s KSeF system represents a significant step towards modernizing the country’s invoicing processes and providing long-term benefits to taxpayers. While change can be challenging, these improvements are designed with a focus on streamlining processes, reducing errors, and enhancing the user experience.

Choose a partner suited to all your needs

To navigate the complexities of the evolving e-invoicing mandate in Poland—and the continuous changes in global compliance—it's crucial for companies to partner with a seasoned expert. Basware boasts over 40 years of experience in e-invoice compliance worldwide.

Our deep expertise ensures businesses can seamlessly adapt to new structures, like the FA(3), while staying compliant with local and international regulations. With proven solutions tailored to meet the specific requirements of diverse markets, including the upcoming KSeF updates, Basware provides the tools and insights necessary to manage compliance efficiently, reduce risk, and stay ahead of future mandates.

Learn more 

In an era of increasingly complex regulations, maintaining tax compliance while driving efficiency is challenging. Our eBook, CFO’s Handbook: Leveraging E-Invoicing for Operational Excellence and Compliance can help you do so with confidence.   

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