On 29 November 2021, the production version of the XSD schema for a structured invoice was released on the website of the Central Repository of Electronic Document Models www.epuap.gov.pl. Consequently, one month before the launch of the National e-Invoice System, the final structure of the new type of invoice is publicly known.
Pursuant to Art. 106nc paragraph. 1 of the VAT Act, entering into force on 1 January 2022, a structured invoice is issued and received using the National e-Invoice System through an interface software, in electronic form and in accordance with the electronic document model within the meaning of the Act of 17 February 2005 on computerization of the activities of entities performing public tasks. Moreover, in accordance with par. 3 of this article of the Act, the minister responsible for public finance provides a structured invoice template on the electronic platform of public administration services.
The first draft of XML schema for structured invoices was published on the website of the Ministry of Finance in early February, while the last major change in the schema fields was released in August.
Compared to the draft version of the schema from August, the production version does not bring any revolutionary changes or significant rearrangements between the main nodes and field groups. However, some changes were introduced to clarify, detail or organize the information, including:
- the data type for the GLN number has been introduced;
- the description for the P_18A field has been updated;
- descriptions of the section fields related to transport has been updated;
- an option to choose the type of address, either Polish or foreign one, has been introduced;
- in the case of a Polish address, the section has been supplemented with additional information such as: voivodeship, county, name of the post office;
- the data type has been changed from character to integer for the fields: types of payment forms, types of loads, types of the bank's own accounts;
- in the case of "Role of a third party" field, the value "7 - Other entity" was removed from the available options;
- the field Agreement Date filed was introduced in the Transaction Terms section.
The publication of the production version of the schema was not accompanied by any communication or announcement from the Ministry of Finance. Together with the XSD schema, the following files were also published: the distinguishing feature file for the pattern in XML format and a transform file specifying the appearance of the electronic document in XSLT format (theoretically allowing to visualize the invoice document).
The publication of the production version of the schema is the next step in the legislative and technical path concerning the National e-Invoices System and the introduction of structured invoices. The Act amending the VAT Act in this respect was recently signed by the President and published in the Journal of Laws. Currently, legislative work is pending with regard to the regulation of the Minister of Finance on the technical details of structural invoices, which is at the draft stage. Pursuant to Art. 106r of the Act, this regulation will specify:
- types of authorizations to use the National e-Invoice System,
- methods of granting, changing or withdrawing authorizations to use the National e-Invoice System and a template of the notification on granting or withdrawing the above authorizations,
- methods of authentication of entities using the National e-Invoice System,
- structured invoice data enabling the access to such invoice in the National e-Invoice System.
The pilot tests of the National System of e-Invoices, which we informed about here (in Polish) are also still in progress.
How can we help?
The introduction of structured invoices will affect many processes related to financial and accounting services in enterprises. As part of our services, we will be happy to assist with regard to:
- review of the currently applied rules and identification of necessary changes,
- support in identifying system and business requirements,
- implementation of the tool for generating structured invoices and communicating with the KSeF (sending and receiving e-invoices) - the tool is being developed and tested as part of the KSeF pilot test program launched by the Ministry of Finance.
Autorzy:
