The Polish Ministry of Finance (MoF) has published a new draft version of the FA(3) logical structure for the National e-Invoicing System (KSeF) on 8 May 2025.
The key changes in the FA(3) draft, compared to the FA(2), are the following:
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Technical Changes – Updates to code formats, schema variants, and data types. For example, a new date type has been added to allow dates from 1990-01-01, which can be used for historical contracts and orders.
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New Features – Added functionalities such as attachments and new identification markers.
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VAT Rate and Payment Improvements – Enhanced VAT codes (e.g. including more specific categories for non-taxable transactions) and additional payment process fields.
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Other Enhancements – Various improvements, such as making the address field optional for Entity3.
This is still a draft and, according to the latest KSeF roadmap, the official FA(3) schema is expected to be released in June 2025, while the launch of the open API testing environment is planned to take place from 30 September 2025.
The new FA(3) structure is scheduled to replace the current FA(2) logical structure on 1 February 2026, when KSeF becomes mandatory for the largest taxpayers in Poland. Additionally, according to the draft of the KSeF simplifying regulations published in early April 2025, the KSeF 1.0 environment will not be shut down as of 1 February 2026 and will continue to store invoices issued under the voluntary model.
Want to understand more about e-invoicing requirements in Poland and how they will impact your business? Read our Sovos e-invoicing in Poland: B2B, B2G, KSeF dedicated webpage.
