Doing business in Poland 2026: 2025 regulatory & tax changes (KSeF, VAT, WHT, Payroll)

2025 delivered a dense package of regulatory reforms and market signals that will reshape operating costs, compliance requirements, and strategic planning for 2026. Tracking these changes is no longer optional: when new rules hit day-to-day finance, HR, and invoicing workflows, the risk of penalties, reporting errors, process disruption, and unexpected tax exposure rises sharply.

For international companies doing business in Poland, the 2025 reforms have immediate implications for accounting in Poland, VAT in Poland, payroll compliance, and cross-border taxes in Poland (including withholding tax, WHT). This review summarises the most important 2025 developments shaping how business is done in Poland—focusing on the obligations and risk areas that intensify in 2026.
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Key regulatory changes in Poland and their impact on business in 2026

The pace of regulatory change in Poland accelerated in 2025 — and for many companies the real consequences will be felt in 2026, when new rules start reshaping day-to-day finance, HR and compliance workflows. Some reforms directly increase operating costs (e.g. fixed contributions), while others raise the bar for documentation, reporting and audit readiness (e.g. invoicing, VAT processes and cross-border tax procedures). For businesses operating in Poland, this means that “knowing the rules” is no longer enough — what matters is whether procedures, systems and responsibilities are in place before the changes hit operational routines.

To make this landscape easier to navigate, the summary below brings together the key 2025 developments that will shape doing business in Poland in 2026. The table highlights the areas affected (accounting, VAT, payroll, HR and cross-border taxes), what changed, and where the most common risk points typically arise — from process disruption and reporting errors to penalty exposure and unexpected tax costs.

Below the table, each topic is explained in more detail, with practical context, compliance considerations and links to in-depth articles covering the specific regulatory changes and their implications for businesses in Poland.

Area	Key change (2025)	Main impact for businesses in 2026	Risk focus
KSeF – e-Invoicing	Mandatory National e-Invoice System (KSeF) from 1 Feb 2026	Full integration of invoicing workflows, ERP systems and VAT processes	Operational disruption, invoicing delays, VAT settlement issues
Health insurance contributions	Increase in minimum contributions for entrepreneurs from 2026	Higher fixed monthly costs regardless of profitability	Cash-flow pressure, reduced profitability for small businesses
Car depreciation limits	New limits linked to CO₂ emissions from 1 Jan 2026	Lower tax deductibility for petrol, diesel and hybrid vehicles	Incorrect emissions data, leasing classification, MDR exposure
Management board liability	New interpretation of Article 116 after CJEU rulings	Greater defence rights, but higher documentation expectations	Personal liability for tax arrears, evidentiary gaps
Withholding tax (WHT)	Stricter approach to cloud services and SaaS	More payments potentially subject to WHT in Poland	Incorrect classification, missing tax residency certificates
Polish-German trade	Record growth in H1 2025	Increased cross-border activity and reporting complexity	VAT, contract settlement, logistics and group reporting errors
Pay transparency	New employer obligations from Dec 2025	Changes to recruitment processes and HR documentation	Non-compliant job ads, discrimination claims
Foreign workers	New employment rules and digitalised permits from 2025	More formal onboarding and reporting duties	Higher penalties, inspection risk
Split payment (VAT)	Extension of mandatory MPP until 2028	Continued liquidity impact and transaction classification duties	Sanctions for misclassification, cash-flow constraints
Electronic delivery address	Mandatory e-Delivery for KRS companies from April 2025	Digital-only official communication with authorities	Missed deadlines, ineffective service of documents
PKD 2025	New classification replacing PKD 2007	Need to update activity codes before automatic reclassification	Incorrect codes, insurance contribution errors
Tax residency certificates	NSA confirms certificate as DTA prerequisite	Stricter WHT procedures before payment	Loss of treaty benefits, over-withholding
PCC on cross-border loans	NSA ruling on loan location in Poland	Potential PCC on intra-group financing	Unexpected PCC cost, treasury documentation gaps

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The National e-Invoice System (KSeF) in Poland mandatory from 1 February 2026 – President signs the law

The President’s signature in 2025 confirmed that mandatory e-invoicing via the National e-Invoice System (KSeF) starts on 1 February 2026, with phased implementation depending on taxpayer size. This is a major process change for companies in Poland: it affects ERP/accounting integrations, internal invoice workflows, exception handling (including offline modes), archiving, and cooperation with contractors. The key business risk for 2026 is disruption—late readiness can trigger bottlenecks in sales invoicing, purchase invoice processing, and VAT settlement timelines. Early preparation in 2025/early 2026 is therefore essential to protect cash flow and continuity.

Learn more about mandatory KSeF e-Invoicing in Poland from February 2026, including implementation timelines, key legal changes and practical guidance for businesses: Poland confirms KSeF e-Invoicing mandatory from 1 Feb 2026

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Increase in health insurance contributions for entrepreneurs in Poland in 2026 – cost impact

The planned increase in minimum health insurance contributions from 2026 is a direct cost driver for many Polish entrepreneurs—especially those settling on a tax scale or flat tax and generating low income or even losses. The key takeaway for management planning is that fixed, unavoidable monthly burdens rise regardless of business performance, which puts pressure on micro and small companies and increases the importance of cash-flow management. For 2026 budgeting, many entrepreneurs will also reassess the chosen taxation form and administrative efficiency, as the cumulative effect of regulatory costs can materially influence profitability.

Learn how the 2026 increase in health insurance contributions for entrepreneurs in Poland will affect businesses, including who will pay more, expected economic impact and practical steps companies can take: Increase in health insurance contributions in Poland 2026.

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Car depreciation limits in Poland from 2026 – rules linked to CO₂ emissions

From 1 January 2026, passenger cars used in business will become less tax-efficient in Poland due to new depreciation and cost recognition limits tied to CO₂ emissions. The higher the emissions, the lower the tax-deductible portion—meaning most petrol, diesel and conventional hybrid cars lose tax advantages, while electric and hydrogen vehicles remain preferred. For companies, this affects fleet strategy, leasing/rental economics, and even procurement timing (especially where transitional rules for operating leases remain unclear). In 2026, car-related tax planning will require technical verification (official emission data) and tighter documentation to avoid disputes and unexpected CIT/PIT exposure.

Learn more about car depreciation limits in Poland from 2026 and their implications for entrepreneurs, including winners and losers, emissions verification rules, leasing and rental, and MDR classification risk: Car depreciation limits in Poland from 2026 – changes and implications for entrepreneurs.

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A member of the management board may defend themselves against the Polish tax authorities – general interpretation by the Minister of Finance

In the 2025 general interpretation (DTS2.8012.5.2025, 29 August 2025), Poland’s Minister of Finance and Economy clarified how Article 116 of the Tax Ordinance should be applied after the CJEU rulings in Adjak and Genzyński. Tax authorities can no longer treat a decision issued against the company as automatically determining a board member’s liability—board members must be allowed to challenge the basis and amount of the arrears and obtain access to case files to the extent necessary for their defence. At the same time, the burden remains on the board member to prove grounds for exemption (e.g., timely bankruptcy/restructuring, lack of fault, or indicating assets for enforcement), so in practice documenting due diligence and key management actions becomes critical for risk management in 2026.

Learn more about the liability of management board members for tax arrears in Poland, including key rules under Article 116 of the Tax Ordinance, the impact of CJEU case law (Adjak and Genzyński), the Minister of Finance’s general interpretation, and what these changes mean in practice for board members: Management board can defend itself before Polish tax authorities.

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Withholding tax (WHT) and cloud services – increasingly strict approach by tax authorities in Poland

Polish tax authorities are increasingly scrutinising payments for cloud services and SaaS, treating them in some cases not as “neutral” service fees but as remuneration for the use of industrial equipment (IT infrastructure such as servers), which may trigger withholding tax (WHT) in Poland. An individual ruling of the Director of National Tax Information (KIS) from 20 May 2025 (ref. 0111-KDIB1-1.4010.139.2025.2.MF) signals a stricter approach: even remote access to cloud-based software can be viewed as falling under Article 21(1)(1) of the Polish CIT Act, making the Polish company responsible for withholding tax. For businesses, this means higher compliance risk in 2026 and a practical need to review contracts, confirm DTA applicability, and secure valid tax residency certificates as part of WHT due diligence.

Learn more about withholding tax (WHT) and cloud services in Poland, including how tax authorities’ approach to new technologies is evolving, the current practice in WHT assessments, and what this stricter interpretation means for businesses operating in Poland: WHT and Cloud Services – stricter rules by Polish tax authorities.

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Polish-German trade gains momentum – record growth in H1 2025

The first half of 2025 confirmed the growing strategic importance of Polish-German trade, with turnover reaching a record level and Poland strengthening its role among Germany’s top partners. For businesses operating in Poland, this trend translates into clear opportunities for export growth and supply-chain positioning, but also elevates the need for robust cross-border tax and finance readiness—especially around VAT, contract settlement terms, logistics planning, and group reporting. Companies expanding into Germany (or supplying German clients) should treat 2026 as a year where operational excellence in documentation and compliance becomes a competitive advantage, not just a legal necessity.

Learn more about Polish-German trade relations and record growth in the first half of 2025, including key export and import trends, Poland’s role as one of Germany’s leading economic partners, and what these developments mean for entrepreneurs and businesses operating in Poland and Germany: Polish-German trade – record growth in the first half of 2025.

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Pay transparency from December 2025 – new obligations for employers in Poland

Amendments published in 2025 introduce pay transparency rules effective 24 December 2025, focusing first on recruitment. Employers must provide candidates with remuneration information (amount or range) and ensure gender-neutral job titles and non-discriminatory recruitment processes, while questions about prior pay become prohibited. For employers operating in Poland, this means updating job ad templates, recruitment scripts, internal documentation, and training HR teams before year-end 2025—so that hiring activity in 2026 runs under compliant rules. These changes are also a “first wave” ahead of broader EU directive implementation expected by June 2026, including potential reporting and enforcement expansion.

Learn more about new pay transparency obligations for employers in Poland from December 2025, including the ban on asking about previous pay, additional requirements introduced by the EU directive (with more changes by June 2026), and practical steps companies can start taking now: Pay transparency from December 2025 – employer obligations.

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New rules for employing foreign workers in Poland from 2025 – law signed by the President

The Act signed in April 2025 reshapes the framework for employing foreign nationals in Poland, with a strong focus on transparency, digitalisation, and enforcement. Employers face new obligations such as submitting employment contract copies before work starts and expanded reporting duties tied to declarations and permits. The reform also strengthens inspection powers and increases penalties substantially, making non-compliance far more expensive in 2026 operations. Companies relying on foreign labour should therefore standardise onboarding documentation, define internal responsibility lines, and prepare for faster and more frequent controls.

Learn more about the new rules for employing foreign workers in Poland from 2025, including the updated list of permissible economic activities, employment contract documentation requirements, new declarations of entrusting work, changes to the work permit process with full digitalization, elimination of the labour market test and stricter penalties for employers: New rules for employing foreign workers in Poland from 2025.

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Split payment mechanism extended until 2028 – implications for VAT taxpayers

The EU Council approved an extension of Poland’s mandatory split payment mechanism (MPP) until 29 February 2028, meaning businesses will continue to apply it for specified “sensitive” goods and services above the statutory invoice threshold. For taxpayers, the key practical impact is ongoing classification risk: misidentifying whether a transaction falls under MPP can trigger sanctions and disrupt settlements. The extension also means that liquidity planning remains important, because VAT funds accumulate in dedicated VAT accounts with restricted use. Additionally, changes to Annex 15 classification (moving toward CN) may drive new interpretative issues—making internal VAT controls especially important in 2026–2028.

Learn more about the split payment mechanism in Poland extended to 2028, including what the mechanism is, its effectiveness, benefits and challenges for taxpayers, and key changes to Annex 15 of the VAT Act: Split payment mechanism in Poland extended to 2028.

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From 1 April 2025, companies registered in the National Court Register in Poland must have an electronic delivery address

As of 1 April 2025, companies registered in the National Court Register (KRS) before 1 January 2025 must have an active electronic delivery address under the Act on Electronic Deliveries. This system is the digital equivalent of registered mail, with full legal effect—meaning “missed inbox oversight” can become a legal and operational risk. For 2026 readiness, the priority is not just creating the address but ensuring governance: appointing the right administrator/roles, implementing monitoring routines, and embedding e-Delivery into corporate document circulation so deadlines and official notices are never overlooked.

Learn more about the requirement for companies registered in the National Court Register in Poland to have an electronic delivery address from 1 April 2025, including the role of the electronic delivery address in communication with authorities, how to obtain it, and the deadline for creation: From 1 April 2025, companies registered in the National Court Register in Poland must have an electronic delivery address.

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New Polish Classification of Economic Activities (PKD 2025) – Key changes and obligations for entrepreneurs

PKD 2025 has been in force since 1 January 2025, replacing PKD 2007 and better aligning classification with EU standards and modern sectors (digital, circular economy, bioeconomy). Businesses have a transition period until the end of 2026, but from 1 January 2027 registers (CEIDG/REGON/KRS) will be reclassified automatically—raising the risk of mismatches for companies whose activity was historically described too broadly. From a business perspective, correct PKD matters for registration accuracy and may impact areas such as accident insurance contribution rates, where classification influences risk group assignment.

Learn more about the new Polish Classification of Economic Activities (PKD 2025), including key changes compared to PKD 2007, new activity groupings aligned with EU (NACE) standards, the transition period until 2026, obligations for entrepreneurs registered in CEIDG, KRS and REGON, and the potential impact on accident insurance contribution rates: New Polish Classification of Economic Activities (PKD 2025).

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Tax residency certificate as a condition for applying DTA to withholding tax – NSA ruling

The Supreme Administrative Court (NSA) confirmed that a valid tax residency certificate is a strict prerequisite for applying Double Taxation Agreement (DTA) preferences in withholding tax (WHT) matters. If the Polish payer lacks the certificate, domestic WHT rates generally apply—even if other extensive documentation exists. For companies in Poland making cross-border payments (dividends, interest, royalties, selected intangible services), this sharply increases the importance of WHT compliance frameworks in 2026: certificate collection before payment, validity monitoring, beneficial owner verification, proper payment classification, and audit-ready documentation.

Learn more about the role of a tax residency certificate in applying Double Taxation Agreements (DTA) to withholding tax (WHT) in Poland, including when a certificate allows DTA application, its impact on the Polish payer’s due diligence obligations, key conclusions from the Supreme Administrative Court ruling (II FSK 47/23), and the most common practical mistakes in WHT procedures: Tax residency certificate as a condition for applying a Double Taxation Agreement (DTA) to withholding tax (WHT) in Poland.

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Loans transferred from Poland to a German subsidiary subject to PCC – NSA ruling

The NSA confirmed that loans granted via bank transfer can still be treated as money located in Poland for civil law transaction tax (PCC) purposes if funds were held in a Polish account at the time the loan agreement was concluded. This is particularly relevant for intra-group financing and cross-border cash flows, where businesses may assume that a foreign borrower automatically removes Polish PCC exposure. For 2026 planning, groups should reassess their financing structures, document where funds are located at transaction moment, and incorporate potential PCC costs and settlement steps into treasury procedures.

Learn more about the Supreme Administrative Court (NSA) ruling that loans transferred from Poland to a German subsidiary are subject to civil law transaction tax (PCC), including the essence of the dispute, developments from tax interpretation to first-instance court decisions, and what the ruling means for taxpayers: Loans transferred from Poland to a German subsidiary are subject to civil law transaction tax (PCC) – Supreme Administrative Court (NSA) ruling.

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What the 2025 changes mean for doing business in Poland in 2026

Across 2025, one trend stood out for companies doing business in Poland: faster, more data-driven enforcement. Poland is accelerating digital tax administration through the National e-Invoicing System (KSeF) in Poland and expanded JPK/VAT reporting, tightening documentation and formal requirements in cross-border taxation (including withholding tax (WHT) and PCC), and extending compliance into HR and supply chains (pay transparency, foreign workers rules and EUDR obligations). For 2026, the winning approach is early operational implementation — systems, procedures and clear accountability — so legal changes don’t turn into business disruption.

We at getsix® help international companies doing business in Poland stay compliant and operationally ready for 2026. We provide end-to-end accounting services in Poland, tax advisory (including VAT and WHT support), HR and payroll services, and company registration in Poland, supported by ongoing reporting and international consulting – both in Poland and cross-border.

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If you have any further questions or require additional information, please contact your business relationship person or use the enquiry form on the HLB Poland website.

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