19 May 2025 Poland releases draft logical structure for e-invoices - On 8 May 2025, the Polish Ministry of Finance released a draft of the new logical structure for e-invoices, FA(3), which will replace the current structure, FA(2), effective 1 February 2026.
- Key changes in FA(3) include the ability to add structured attachments to invoices, a new role for identifying employee-related expenses and a 50,000-line limit for collective correction invoices.
- The updated structure also introduces new fields for payment deadlines, payment methods for partial payments and an expanded VAT-rates dictionary, streamlining the invoicing process for businesses.
- Companies must prepare for significant changes in their invoicing processes, documentation and technology, making it essential to engage specialists to address the new e-invoicing requirements.
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On 8 May 2025, the Polish Ministry of Finance released a draft version of the logical structure for e-invoices, FA(3), which as of 1 February 2026, will replace the currently applicable logical structure, FA(2). The new structure takes into account feedback the Ministry received during tax consultations, as well as suggestions raised in meetings with business organizations, accountants, auditors and the information technology (IT) sector. Changes from the previous version of the schema, FA(2), include: - The ability to add attachments (structured) to an invoice
- A new role allowing employee designation to identify so-called employee-related expenses
- A new 50,000-line limit for a single collective correction invoice
- Removal of the requirement to provide an address for third parties
- Two new fields related to payment deadlines — a payment link and a National e-Invoice System (KSeF) payment identifier
- New fields enabling the presentation of the payment method separately for each partial payment, and a change to the partial-payment flag to accommodate scenarios where partial payments cover the full amount due
- Expanded VAT-rates dictionary
- Changes to indicators for whether an invoice pertains to a subordinate unit of a local government entity (JST) in the buyer's data or to a VAT group member
The Polish Ministry of Finance has also made available: - The structure documentation
- An informational brochure
- New sample invoices (XML), including the use of the new "Attachment" element
- A summary of selected changes compared to FA(2)
The Ministry of Finance materials are available here (in Polish only). The new version of the schema is one of the key elements that has, so far, delayed the implementation of e-invoicing in some entities. This information will allow such projects to accelerate, which is crucial for timely preparation for the new invoicing requirements. Implementing e-invoicing within an organization requires significant changes to process, documentation and technology. Therefore, it is advisable for businesses to rely on specialists in this area. | * * * * * * * * * * | | Contact Information | For additional information concerning this Alert, please contact: EY Doradztwo Podatkowe Krupa sp.k., Warsaw | | Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor |
Document ID: 2025-1095 |
