06.27.23

New draft version of XML schema FA(2)

The Polish schema has been subject to much scrutiny when the Polish e-invoicing mandate was announced. Given that it is based predominantly on the SAFT-reporting file in Poland, it contains many more fields than would typically be expected to be seen in an invoice, including numerous fields which unrelated to VAT, such as excise and customs information. Given this background, and as is typical practice for countries undergoing e-invoicing implementation, it is not surprising that the Polish schema would undergo some revisions.    

 On 23 May 2023, a new draft version of XML schema for the Polish e-invoice (FA2) was published on the webpage of the Ministry of Finance. The publication of the new schema will allow IT systems to adapt to the new changes in line with the new obligations. The final version of XML schema is set to be published in June 2023 and become binding for the issued and received e-invoices from 1 September 2023. This therefore includes the voluntary period of KSeF, which is expected to last until 1 July 2024.   

 The implementation curvature for FA(2) is expected to be in line with the following:   

• 23 May 2023: the release of the new draft version of FA(2) logical structure   
• June 2023: the new logical structure is expected to be officially published on ePUAP website  

• July 2023: the test environment adapted to the new logical structure is expected to be rolled out, along with the relevant documentation  
• 1 September 2023: the production environment supporting the new version of the FA(2) logical structure is expected to be released.  

 Therefore, from 1 September 2023, a new version of the FA(2) logical structure will be binding for the purposes of issuing e-invoices via KSeF and will effectively replace the FA(1) logical structure.  

Changes in the draft of FA(2) compared to the FA(2) submitted for consultation in December 2022 along with the technical documentation have been published on the Ministry of Finance website, but yet are available in Polish only.   

Kofax has defined the differences between the old and the new schema and is currently analysing these with a view as to what effect this will have on our e-invoicing implementation.