What is a structured invoice?

A structured invoice is currently one of several available forms of documenting business transactions (in addition to paper invoices and electronic invoices). A structured invoice is considered to be an invoice issued using the National e-Invoice System (KSeF) with an assigned unique number identifying the invoice in the system (the so-called KSeF number). The KSeF number consists of 36 characters and is assigned automatically by the system.

What types of fields are provided for in the schema of a structured invoice?

A structured invoice is issued in XML format following the logical structure (schema) published by the Ministry of Finance. The logical structure contains three types of fields: mandatory, contingent, and optional.

Mandatory fields include mandatory elements that, according to VAT regulations, every invoice should contain. Failure to fill in such a field will prevent an invoice from being successfully sent.

Contingent fields are fields that should be mandatorily filled in if certain prerequisites under the regulations are met. The omission of such a field will not result in the rejection of the invoice by KSeF, but it will be issued defectively under the regulations.

Optional fields are intended for information that is not compulsory to be included on an invoice and is entirely at the discretion of the taxable person. These are the information that is already commonly used in practice on invoices (e.g. date of payment, bank account number for payment, terms and conditions of the transaction). It is worth noting that the schema has been prepared in line with the idea that for most of the optional (not required by the VAT rules) elements already commonly used in practice on invoices, an appropriate field has been provided for them.

Therefore, already at the stage of KSeF implementation, it is worth considering which fields – in addition to the mandatory ones – should be filled in to ensure compliance of the invoice content with the law or for other reasons, e.g. as additional information for the counterparty.

The moment of issuance and receipt of the structured invoice

The date of issuance of a structured invoice will be the date it is sent to KSeF. On the other hand, the date of receipt of a structured invoice using KSeF will be the date on which the invoice is assigned a KSeF number. However, there will be exceptions to the above rules.

For invoices issued during a period of failure or in the so-called offline mode, the date of issue will be the date indicated by the taxpayer on the invoice in field P_1. The date of receipt of such an invoice, on the other hand, will be considered the date of actual receipt of the invoice by the buyer. However, if the date of actual receipt of the invoice is later than the date of assignment of a KSeF number to that invoice, the date of receipt will generally be the earlier date.

How will a structured invoice be issued?

To issue a structured invoice, taxpayers will be able to use a free platform created by the Ministry of Finance. In practice, this option will be used more by taxpayers with very small-scale operations. Most taxpayers, however, will use commercial software for this purpose, which should make it possible not only to issue an invoice by the scheme but also to send it to KSeF.