Poland has taken another step toward its B2B e-invoicing mandate with the publication of the draft FA(3) schema by the Ministry of Finance on May 8, 2025. This format will serve as the official invoice format for submissions to KSeF (Krajowy System e-Faktur) once the mandate takes effect.
Under the planned 3-corner model, invoices will be submitted by the invoice sender to the government-run KSeF platform, which will handle validation, assign a unique identifier, and archive each invoice for a period of 10 years. Once processed, the invoice will be delivered to the recipient through KSeF.
Summary of changes
The FA(3) schema draft introduces, among other changes:
- Additional VAT codes
- New options for attachments
- Changes to data types
- Updated payment field options
- Clarified rules for duplicate invoices
These changes follow previous consultation rounds and are supported by documentation such as invoice samples, a summary of changes from FA(2), and an informational brochure.
However, the newest draft still does not include alignment with EN 16931. It can therefore be assumed that norm compliance is not planned for the time being.
The final version of the schema (along with API documentation for the interface specifications of KSeF 2.0) is planned for publication in June 2025, will FA(3) will definitely replace FA(2) in February 2026, coinciding with the start of the mandate.
Mandate Timeline Remains Tight
The mandate has faced multiple delays, resulting in an ambitious timeline for implementation. With the legislative process expected to conclude by July 2025, only a short window remains for testing and rollout, before e-invoicing becomes mandatory following a phased roll-out:
- February 1, 2026: large taxpayers (PLN 200M+ / ~47M€ turnover in 2024)
- April 1, 2026: all other taxpayers (excluding those listed below)
- January 2027: micro-businesses (invoices under PLN 450 / ~106€ and sales under PLN 10,000 / ~2364€ per month), cash register integration, and mandatory use of KSeF invoice numbers
Poland has also announced a grace period, during which no sanctions will be imposed for non-compliance with the B2B e-invoicing mandate. Penalties will begin in January 2027.
For more details on the upcoming mandate, check out our Poland country profile and follow The Invoicing Hub on LinkedIn to stay updated.
