Business Review Poland – March 2026

March 2026 brought several important tax, legal and HR developments in Poland. For businesses, this means an increasing need to monitor regulatory changes closely, not only from the perspective of formal compliance, but also in terms of process organisation, data quality and practical readiness to respond to new obligations.

In this review, we present the most important developments from the past month that are shaping the conditions for doing business in Poland.

Tax audits by Poland’s National Revenue Administration (KAS): how companies should prepare in 2026

According to official 2025 figures, the total value of findings from customs and fiscal audits, tax audits and verification activities increased by 29.1% year on year, from PLN 14.76 billion in 2024 to PLN 19.05 billion in 2025, while the total number of actions rose by 9.4%, from more than 2.41 million to nearly 2.64 million. At the same time, the number of customs and fiscal audits fell by 27.4% (from 7,043 to 5,113), yet the value of findings in these audits increased by 46.4%. This clearly shows that KAS is selecting cases more precisely before starting formal proceedings. From 1 February 2026, the implementation phase of mandatory National e-Invoicing System (KSeF) in Poland began, while JPK_CIT obligations are also being rolled out gradually, with the first JPK_KR_PD structures expected to be submitted in 2026 for financial years beginning after 31 December 2024. For companies, this means that tax risk now increasingly arises from data mismatches, weak document flows, manual adjustments without justification or inconsistencies between accounting books, VAT records and tax returns.

Read the article for more details: Tax audits by Poland’s National Revenue Administration (KAS).

End of the Ukrainian Special Act in Poland – what it means for employers

On 19 February 2026, the President signed the act phasing out the extraordinary solutions introduced under the so-called Ukrainian Special Act, and the new rules were expected to apply from 5 March 2026. For employers, the main issue is not a sudden loss of employment continuity, but the need to move from emergency measures to a more system-based approach for foreigners under temporary protection. The act is expected to preserve the effects of actions taken before 5 March 2026, including notifications already submitted, but companies still need to review residence documents, work entitlement records and internal HR/payroll procedures. A particularly important practical point is the notification of entrusting work, which remains a simplified route to legal work, but failure to submit it may lead to a fine of PLN 1,000 to PLN 3,000. Employers should also pay close attention to postings and longer business travel, because temporary protection may expire if a beneficiary leaves Poland for more than 30 days. The planning horizon is also important: temporary protection is expected to remain in place until 4 March 2027, giving businesses time to prepare longer-term residence and work solutions for selected employees.

Read the article for more details: End of the Ukrainian Special Act in Poland (2026): Employer guide.

Cash equivalent for unused annual leave after the 2026 changes in Poland – deadlines, exceptions and practical concerns

Following amendments to the Polish Labour Code, from 27 January 2026 the cash equivalent for unused annual leave should generally be paid on the employer’s regular payroll date. This is a practical change for HR and payroll teams, because the previous approach often linked payment more directly to the employment termination date. The new rules also provide an exception: if the payroll date falls before the date of termination or expiry of the employment relationship, the equivalent should be paid within 10 days from the date of termination or expiry of employment. If the payment date falls on a non-working day, the payment should be made on the preceding working day. For example, if employment ends on 31 March 2026 and the regular payroll date falls on 5 April 2026, the equivalent should be paid on 3 April 2026, because 5 April 2026 falls on a Sunday. In practice, the amendment means employers should review their offboarding and payroll procedures carefully, especially where contracts end in the middle of the month or where final settlements are processed outside the standard salary cycle.

Read the article for more details: Unused leave compensation in Poland 2026 – new rules.

Tax relief for returning to Poland: when the Polish tax office may challenge the PIT exemption

Tax relief for returning to Poland remains an attractive preference, but it is also increasingly scrutinised by the tax authorities. The relief provides an exemption from Polish PIT on qualifying income up to PLN 85,528 per year, available for four consecutive tax years. According to the Ministry of Finance, it applies to individuals who moved their place of residence to Poland after 31 December 2021, but only if all statutory conditions are met jointly, including the requirement that the taxpayer did not have a place of residence in Poland during the required period and can document foreign tax residence properly. In practice, the central issue is not the fact of working abroad for several years, but whether the taxpayer genuinely lost Polish tax residence earlier and only then transferred it back to Poland. This approach can be seen in individual tax ruling no. 0115-KDIT2.4011.725.2025.2.KC concerning a taxpayer returning from Norway, and in ruling no. 0113-KDWPT.4011.294.2025.3.ASZ concerning a taxpayer returning from the United Kingdom. In both cases, the authorities found that family ties in Poland meant that the centre of personal interests had remained in Poland. The same direction is visible in the judgment of the Voivodeship Administrative Court in Gdańsk, case I SA/Gd 708/25, where long-term work in the Netherlands was not enough to confirm an effective transfer of tax residence. For taxpayers and entrepreneurs, the message is clear: facts, family circumstances and documentation matter more than the declared moving date.

Read the article for more details: Tax relief for returning to Poland – PIT risks.

Partner remuneration for managing the company as hidden profits under Estonian CIT in Poland

A major interpretative risk has emerged for taxpayers using the Estonian CIT regime in Poland. In an amending interpretation issued by the Head of the National Revenue Administration on 7 November 2025 (ref. DOP12.8221.9.2025), the authority concluded that remuneration paid to a partner for managing the affairs of a limited partnership may be treated as hidden profits and therefore taxed under the lump-sum corporate income tax framework. This is particularly important because the authority focused not on whether the work was real or whether the remuneration was set on market terms, but on whether the entitlement to that remuneration arose from the person’s status as a partner and their influence over the entity’s functioning. The interpretation also made clear that the risk is not limited to cash payments: non-cash benefits may also be challenged if they create a measurable economic benefit for the partner at the expense of the entity. For limited partnerships and other taxpayers under Estonian CIT, this means it is necessary to review all value transfers to partners, the legal basis for these settlements, their documentation and the overall consistency of the settlement model before a dispute arises.

Read the article for more details: Hidden profits in Estonian CIT Poland: partner pay risk.

The developments seen in March confirm a clear direction: the Polish business environment is becoming more data-driven, more compliance-focused and more sensitive to inconsistencies between legal, tax and operational practice. For companies, this means that readiness, internal clarity and well-structured processes are becoming just as important as the formal correctness of individual settlements.

At getsix®, we support companies by providing a full range of services in accounting, taxes, HR and payroll Poland, as well as company registrations, administrative support, reporting and international consulting both in Poland and abroad.

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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