The Ministry of Finance has published a proposal for technical documentation concerning the collective identifier in KSeF 2.0. This is the first document presenting technical details related to the generation, search and handling of collective identifiers through the KSeF API. The publication is of significant importance for businesses preparing for mandatory KSeF, as it allows them to begin analysing the impact of the new requirements on ERP systems, payment processes and integration solutions.
At the same time, the Ministry of Finance is conducting consultations with software vendors and integrators; therefore, the current shape of the solution should be treated as a proposal that may still be subject to change.
What is the KSeF collective identifier?
The collective identifier functionality is directly related to the planned obligation, effective from 1 January 2027, to indicate either the KSeF number or a collective identifier in the payment reference for structured invoices. The solution is intended to simplify payments covering a larger number of invoices and reduce the need to include multiple KSeF numbers in banking communications.
What follows from the published documentation proposal?
According to the published specification, a dedicated API area for handling collective identifiers will be made available in KSeF 2.0. The documentation describes operations enabling the generation of identifiers, retrieval of the list of created identifiers, verification of invoices assigned to a specific identifier and searching for identifiers linked to a selected KSeF number.
According to the presented assumptions:
- a collective identifier is generated for a list of KSeF invoice numbers issued by the same seller,
- according to the published documentation, the maximum number of invoices assigned to one collective identifier is 200; at the same time, during the ongoing consultations, it was announced that the limit will be increased to 500 invoices, and further increases are being analysed for selected business scenarios,
- one invoice may be assigned to a maximum of 132 collective identifiers within one context,
- the collective identifier has the following format: TIN-CIYYYYMM-FFFFFFFFFFFF-FF,
- the identifier structure contains information about the seller’s TIN as well as the year and month of its creation,
- appropriate permissions in KSeF, including CollectiveIdentifierManage, are required to generate, search and retrieve identifiers; according to information provided during the consultations, operations on collective identifiers may also be performed by entities holding the InvoiceWrite permission,
- it is possible to retrieve a list of collective identifiers generated within a specified time period, with filtering available by, among others, identifier number and number of invoices,
- it is possible to retrieve a list of KSeF numbers assigned to a specific collective identifier,
- it is possible to search for all identifiers linked to a specific KSeF number,
- information regarding the payment amount and currency is made available only to the entity that created the collective identifier or to an entity acting in a specific role on the invoice; in other cases, payment details may be hidden.
Which issues remain open?
Despite the publication of the technical details, many important business aspects remain under consultation. Discussions conducted by integrators and software vendors focus, among others, on the possibility of including documents other than KSeF invoices (e.g. accounting notes or interest notes), handling partial payments, storing additional business information used in ERP systems and supporting mass-processing scenarios.
Questions also remain regarding the rules for generating collective identifiers in the case of refunds, set-offs and corrective invoices, as well as the final limits on the number of invoices that may be assigned to a single identifier. At this stage, the Ministry of Finance has not yet presented final decisions on these matters.
How can PwC help?
The publication of the proposal for the technical documentation of the collective identifier is a good opportunity to assess the impact of the new KSeF 2.0 requirements on financial processes, ERP systems and payment solutions within the organisation. Although some topics remain under consultation, businesses can already begin preparatory activities.
PwC supports organisations in:
- analysing the impact of the new KSeF 2.0 requirements on sales, procurement and payment processes,
- assessing the readiness of ERP systems and integration solutions to support collective identifiers and new payment-related obligations,
- designing target business processes, including mass payments, corrective invoices, set-offs and other specific scenarios,
- supporting the implementation and testing of KSeF solutions, including integration with financial, accounting and banking systems,
- monitoring legislative and technical developments and continuously adapting organisations to evolving requirements.
Given the dynamic nature of the work related to KSeF 2.0, ongoing analysis of published materials and early preparation for upcoming changes are of key importance. PwC continuously monitors the progress of the Ministry of Finance’s work and participates in market discussions regarding the practical aspects of implementing the new solutions.
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