A new type of transaction evidence has been introduced, with effect as of 1 January 2022, i.e. structured invoices. The law underlying this new type of document was signed by the President on 15 November 2021 and is coming into force on 1 January 2022. Accordingly, as of that day, taxable persons will be able to use structured invoices in addition to paper invoices and electronic invoices to document their transactions.
The Finance Ministry (FM) and the National Revenue Administration (NRS) held a webinar on 25 November 2021 on the operation of the National e-Invoicing System (KSeF) and the practicalities of implementing structured invoices in the accounting environment.
A number of matters were addressed during the webinar. For example, the authorities confirmed that:
- electronic invoicing based on a structured invoice template will become generally available as of Q2 2023 (initially this was supposed to be early 2023);
- additional (customised) invoice content may be placed in the optional fields of the FA_VAT schema;
- structured invoices may be dispatched to KSeF in batches, with receipt acknowledged via a batch UPO (official acknowledgment of receipt);
- an invoice issued in KSeF (i.e. having its unique KSeF number assigned) may not be withdrawn, edited or removed and any such revisions must be done via a correcting invoice;
- access to KSeF may be authorised using a trusted profile, a qualified signature, a qualified signature without NIP/PESEL attribute but with a different authentication method (e.g. fingerprint), a qualified seal, or a token. There are plans to accept also foreign e-signatures.
A test KSeF environment at https://www.podatki.gov.pl/ksef/strefa-testowa-ksef/ has been made available to businesses as a pilot program and plans are in place to soon launch an API demo and a test version of the Podatnik KSeF application. The final versions of the API and the application are scheduled to be made available in early 2022.
In addition to properly implementing the FA_VAT schema in their accounting and finance software, businesses need to ensure they are prepared for interfacing with the KSeF system and, most importantly, that all data and information sent or received remain safe.
If these issues pertain to your business and you are interested in our assistance, please contact us.
This blog post is provided for general information purposes to keep you up-to-date with changes in tax law, tax rulings by authorities, case law of courts and interesting commentaries. Doradztwo Podatkowe WTS&SAJA shall not be held legally liable for any acts or omissions resulting from reliance on such information.