- Entity3 field complexity: Sellers issuing invoices to municipalities via KSeF are not legally required to complete the “Entity3” field (subordinate units like schools or sports centers). The Ministry of Finance recommends including it when “Entity2” indicates a subordinate unit, but this remains optional. This creates potential difficulties in correctly assigning invoices to subordinate units
- Invoice structure for local governments: In the FA(3) format, Entity1 = seller, Entity2 = local government unit (with NIP), and Entity3 = optional subordinate unit (with NIP or internal ID). Municipalities and their units can access invoices via the main NIP or the internal ID (IDWew). Lack of consistent implementation in accounting software adds uncertainty.
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Concerns remain: Local governments worry about liability, reporting, and proper cost settlement if subordinate unit data is missing. Early KSeF implementation may cause organizational and technical challenges, as some contractors and software providers have not yet fully adapted to optional subordinate unit fields.
Source Prawo
Briefing document & Podcast: Poland E-Invoicing, E-Reporting and KSeF Mandate – VATupdate
- See also
- Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE
- Join the LinkedIn Group on ”VAT in the Digital Age” (VIDA), click HERE
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