The long-awaited update to the structured invoice format – FA(3) in KSeF – has come into effect.
The new version, developed by the Ministry of Finance, expands the technical capabilities of invoicing, including support for attachments, QR codes, and fields supporting emergency mode (offline24).
Although these changes are evolutionary in relation to version FA(2), their practical implications are significant, particularly for organizations operating in SAP environments.
For teams responsible for integration with KSeF, this means not only adapting the XML structure and processes, but also reconsidering data security, user interface design, and cooperation with accounting and compliance departments.
In this article, we examine the key changes in FA(3) and show how to effectively adapt to the new requirements, based on HAERGI’s implementation experience in SAP environments.
New capabilities of FA(3): what’s changing?
FA(3) introduces several long-awaited functionalities that until now were only possible outside the KSeF structure. In particular, these include:
- the ability to attach files to invoices,
- placing QR codes that identify the invoice,
- adding new fields in metadata – for payments and recipient identifiers (e.g., in public administration),
- support for emergency mode – i.e., scenarios in which sending to KSeF is temporarily impossible.
These changes affect the XML data structure, processing procedures in SAP, and rules for document visualization and archiving.
Attachments – a new standard for supporting documents
Attaching files to invoices has been one of the most common requests from businesses. Thanks to FA(3), it is now possible to send, for example, delivery specifications, photos, or acceptance protocols along with the main invoice.
However, implementing this feature requires fulfilling several formal conditions – to use this functionality, an application must be submitted to the Ministry of Finance (via API). Moreover, the Ministry has imposed restrictions on the format and size of attachments. This means that not just any attachment can be included with a KSeF invoice.
From the SAP perspective, the HAERGI solution provides an intuitive interface for adding attachments, automatically linking them to the invoice, and logging transmission errors in the system log. The user does not have to manually create references in the XML – the system handles it.
QR codes – support for identification and offline operations
Another new feature is the requirement to include a QR code identifying the invoice. This applies primarily to offline scenarios (offline24 mode), but also to the standard invoice flow – e.g., when the buyer receives a printout or PDF version.
The QR code contains data identifying the KSeF invoice. Once the invoice is approved by KSeF, HAERGI automatically generates the code in SAP and integrates it into the invoice printout. The code can also be previewed in the user interface.
SAP environment update – what needs to change?
To support FA(3), the technical layer of SAP must be adjusted:
- updating XML and XSD schemas,
- changing data mapping in extensions (BAdI),
- testing communication with the Ministry of Finance’s demo system.
HAERGI offers ready-made extensions enabling rapid implementation of FA(3), with the possibility of simultaneous testing and ongoing production use.
FA(3) in KSeF – emergency mode (offline24)
One of the most significant changes in FA(3) is the introduction of offline mode, which allows issuing an invoice when access to KSeF is unavailable. In such cases, the invoice must be registered in the system within 24 hours of issuance.
In practice, this means:
- the possibility of issuing the invoice locally in SAP,
- marking it as “offline” in the XML structure,
- generating a QR code without KSeF confirmation,
- later, automatic transmission of the invoice to the Ministry’s system.
The HAERGI solution supports this process fully automatically, helping avoid the risk of errors due to delays or manual intervention.
How to prepare your organization for KSeF and FA(3)?
Implementing FA(3) is a process that should be planned well in advance. Here are a few best practices:
- test the XML structure, attachments, and QR codes in the MF demo environment,
- identify processes that will require attachments – e.g., cost invoices, investment projects,
- test the new invoice template including the QR code,
- train accounting and IT teams.
Structured invoices in version FA(3) introduce many conveniences but also require specific actions from companies using SAP. Handling attachments, QR codes, and offline mode means not only new technical features but also the need for additional integration testing with KSeF.
The HAERGI solution supports all these elements – from structure updates to automated communication with KSeF. It is advisable to begin the FA(3) implementation process now, before it becomes mandatory.
