Poland’s Ministry of Finance has released a draft version of the FA(3) schema for structured e-Invoicing within the KSeF platform, replacing the current FA(2) version. According to the latest announcement by Poland’s Ministry of Finance, the FA(3) schema will become mandatory starting from February 1, 2026, replacing FA(2) as the standard format for all structured e-invoices transmitted via the KSeF platform.
This new version introduces significant enhancements aimed at improving data accuracy, alignment with business practices, and interoperability. Below is a structured analysis of what’s new in FA(3) and how it compares to FA(2).
Schema Identification and Technical Versioning
The FA(3) schema introduces a clear change in technical versioning:
- kodSystemowy is updated to “FA(3)”, replacing “FA(2)”.
- This helps systems identify and validate against the correct structure.
Invoice Metadata and New Fields
Several new metadata fields have been introduced to enhance the context of the invoice:
- IPKSeF: A unique payment identifier generated by the KSeF system.
- DataUmowy (Contract Date) and DataZamowienia (Order Date): These fields now allow entering contract/order dates starting from 1990, improving historical data tracking.
Attachments Now Supported
A major functional improvement is the support for invoice attachments:
- The new <Zalacznik> tag enables attaching supporting documents directly to an invoice in KSeF.
- This addresses a key business need, especially in B2B workflows where contracts, proof of delivery, or specifications may accompany an invoice.
Extended Payment Details
The FA(3) version enhances payment-related information:
- A payment link field (LinkDoPlatnosci) allows e-Invoices to include URLs for online payments.
- Partial payment structure changes: The PartialPaymentMarker can now distinguish between partially paid and fully paid (in parts) scenarios.
- New options for FormaPlatnosci and PlatnoscInna (payment method and alternative payment) allow more accurate modeling of payment types.
Expanded VAT Rate Dictionary
FA(3) significantly extends the dictionary of VAT rate values:
- Several new VAT classification codes were added.
- The expanded dictionary aligns better with invoice summary data.
Changes to Entity Roles and VAT Group Handling
Entity tagging is more precise in FA(3):
- New role values for Entity3 allow identifying employee-related expenses.
- The GV and JST tags now support clearer differentiation for VAT groups and local government units. This includes reversed marker logic compared to FA(2) to align with user feedback during consultation.
Correction Invoice Enhancements
The correction process has been clarified and technically limited:
- The number of corrected invoice records (DaneFaKorygowanej) is now limited to 50,000, preventing system overload.
- For corrections involving buyer information (Entity2 or Entity3), full original data must be provided, not just differences.
Bank Account and Tax ID Validations Updated
- Bank account numbers now accept longer formats with special characters, accommodating international IBAN and SWIFT standards.
- Tax ID field formats (TNrRB) have been updated for broader compatibility and better validation.
Flexible Payment Deadline Descriptions
FA(3) introduces a more flexible approach to payment terms:
- Instead of a fixed date, a new structure allows describing the payment term in relation to a specific event (e.g., contract signing, delivery) and time unit (e.g., 14 days after X).
The draft FA(3) schema not only enhances data quality and system reliability but also bridges gaps between real-world invoicing practices and digital reporting obligations. Businesses should begin reviewing these changes to ensure readiness ahead of FA(3)’s eventual enforcement.
For official schema and updates, visit: ksef.podatki.gov.pl/robocza-wersja-struktury-logicznej-fa-3/
