Business Review Poland – July 2026

July 2026 brought new AI-content duties, broader PIP inspection powers, preparations for KSeF references in split payments, a narrower MDR regime and greater risk around 100% VAT deductions for company cars. The key dates are 2 August 2026, 1 October 2026 and 1 January 2027.

For businesses managing accounting in Poland, payroll, tax and corporate compliance, records must reflect actual operations as authorities increasingly combine data from different systems.

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What AI Act duties apply from 2 August 2026?

Article 50 covers the marking of synthetic content, deepfakes and certain public-interest texts. Providers of generative tools must use machine-readable marking, while companies publishing content remain responsible for visible disclosure.

A transition until 2 December 2026 applies to certain systems already on the market. Fines may reach EUR 15 million or 3% of worldwide annual turnover.

Companies should map their AI use, define disclosure rules and appoint a person responsible for approval and documentation.

Read more: AI Act transparency obligations in Poland from 2 August 2026.

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How did PIP inspections change on 8 July?

PIP can conduct remote checks, select entities analytically, exchange more information with ZUS and the tax administration, and challenge sham civil-law contracts or B2B arrangements.

Fines increased to PLN 2,000–60,000, rising to PLN 90,000 for a repeat offence within two years. Employment documents should match how work is actually performed.

Read more: PIP inspections in Poland: new rules from 8 July 2026.

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How will KSeF change split payments from 1 January 2027?

For a single structured invoice, the payment message will use the KSeF number. For batch payments, a collective identifier generated by KSeF will replace the list of invoice numbers.

Mandatory split payment still applies to transactions between taxable persons above PLN 15,000 involving goods or services listed in Annex 15 to the VAT Act. The mechanism has been extended through 2028.

Businesses should test their accounting, payment-approval and e-banking integrations.

Read more: Split payment mechanism and KSeF invoices in Poland.

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What changes in MDR reporting from 1 October 2026?

MDR will generally cover only cross-border arrangements. Domestic schemes, VAT and excise will leave the scope. The supporter role, mandatory internal procedure and MDR-2 form will be removed.

MDR-3 will normally be filed annually by the end of the fourth month after year-end and may be signed by a proxy. Some duties due by 30 October 2026 must still follow the former rules.

The maximum fine is 720 daily rates, theoretically up to PLN 46,137,600.

Read more: MDR changes in Poland 2026: what companies must do.

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When is a 100% VAT deduction for a company car at risk?

Full recovery requires exclusive business use, timely VAT-26 filing, reliable mileage records and an effectively enforced ban on private journeys.

VAT-26 must be filed by the 25th day of the following month, no later than the date the VAT records are submitted. Authorities can compare mileage logs with automatic number plate recognition data.

Discrepancies or even one private trip may reduce the deduction to 50%, with interest and possible fiscal-penal consequences.

Read more: VAT deduction for company cars in Poland.

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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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