Following the numerous suggestions made during the public consultations held in February and March 2024, it has been decided update the FA structure due to the multiple faults found in the system.
In this context, the Ministry of Finance's regulation dated December 27, 2021 on the use of KSEF will be repealed and replaced with a new one, which will include regulations on:
- QR codes.
- Two-step authorization access for invoices.
- Regulations on internal certificates.
- The presentation of the payment deadline.
- Introduction of a new role in the Podmiot3 node (entity 3) — employee (an important solution for identifying employee expenses).
- An increase in the number of possible characters in the P_7 field (name of goods or services).
- Solutions dedicated to Local Government Units and VAT Groups.
- It is also contemplated to add new functionality so that attachments can be sent to the KSeF.
The Ministry of Finance has made this available to the public FAQ, which answers many of the questions that arise as a result of these new changes.
Among others, it is confirmed that the new KSeF scheme FA (3) format will be released for public consultation in the fall of this year.
In addition to all the suggestions received as a result of the public consultation, an audit was carried out in which irregularities in the IT architecture were revealed, affecting performance, as well as security, leading to a high failure rate, low maintenance capacity, and problems with the development of the future system and its recoverability. It is because of all this that the decision has been made to rebuild the system architecture from scratch, thanks to the hiring of a team of specialists who will improve the reliability, security and functionality of the system.
According to the Ministry of Finance, these changes are expected to be beneficial for taxpayers. Therefore, in light of this new scenario, the new dates scheduled for the mandatory implementation of the KSeF are:
- As of February 1, 2026 for entrepreneurs with sales exceeding PLN 200 million in 2025.
- As of April 1, 2026 for other entrepreneurs.
From Brait, we will continue to inform you of the news about the Electronic Invoicing in Poland and other countries, but if you have any questions, do not hesitate to contact us, we would be happy to introduce you to our solution for electronic invoicing at SAP, Invictia by Brait.
