Structured e-invoices

New type of invoices – structured e-invoices

A structured e-invoice is a new type of electronic invoice (a new definition has been incorporated into the applicable VAT regulations) that is to be used during the transition period alongside traditional (paper) invoices and non-structured e-invoices. A distinguishing feature of structured e-invoices is that they will be issued based on the template proposed by the Ministry of Finance. Before raising structured e-invoices, the taxpayer will be required to submit relevant notifications to the tax authorities and to seek the recipient’s acceptance of such e-invoices. Once the e-invoice is sent to KSeF, it will be assigned an identification number and a date of issue. A structured e-invoice will be considered issued on the date when it is sent to KSeF and received on the date when an ID number is assigned to it by KSeF.

Structured invoices will be raised by taxpayers in their accounting systems (in the form set out by the Ministry of Finance) and submitted to the National System of e-Invoices via application programming interface (API), which is an interface enabling a connection and exchange of data between IT systems. The new system will also enable verification and approval of invoices as well as their release into legal circulation. The taxpayer will be able to view issued and received structured e-invoices following authentication in KSeF, as well.
To enable taxpayers to adapt their accounting systems to the changes, the Ministry of Finance has published a draft version of the logical structure of the e-invoice with a set of sample structured e-invoice files, illustrating how the structure should be filled in.

Structured e-invoices – benefits for taxpayers

Taxpayers issuing structured e-invoices may derive the following benefits:

• a reduced VAT refund period of 40 days (instead of 60 days) – provided that specific conditions have been met;
• no obligation to issue duplicates for structured e-invoices;
• no need to store and archive invoices for ten years, as this obligation will be imposed on the tax administration;
• no obligation to submit, at the request of tax authorities, JPK_FA files for taxpayers issuing all their invoices in the structured e-invoice format;
• simplified correction of the tax base and VAT by the buyer/seller;
• certainty that the invoice has been received by the relevant party;
• certainty that invoices are raised based on a single template and thus elimination of the risk that a failure to provide specific information in the invoice will lead to negative consequences.

The launch of structured e-invoices comes with many benefits, but it also requires changes to the taxpayers’ accounting systems. It will also offer a number of advantages to the tax authorities since all the data will be available in the National System of e-Invoices.

What can we expect in the future?

During the transition period i.e., until the end of 2022, the use of the National System of e-Invoices and structured
e-invoices is optional. As from January 2023, the system is expected to become mandatory. However, for the time being, such expectations are not based on any legislative changes, but on the Ministry of Finance ’s media releases.