Business Review Poland 2025: Poland’s regulatory and economic highlights shaping 2026

2025 brought a dense package of regulatory reforms and market signals that directly affect operating costs, compliance duties, and strategic planning for 2026. Keeping track of these changes is no longer optional: the risk of penalties, reporting errors, process disruptions, and unexpected tax exposure increases sharply when new rules collide with everyday finance, HR, and invoicing workflows.

In this review, we present the most important 2025 developments shaping how business is done in Poland—especially with a view to obligations and risks that intensify in 2026.

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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.

Read the article for more details: 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.

Read the article for more details: 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.

Read the article for more details: 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.

Read the article for more details: 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.

Read the article for more details: 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.

Read the article for more details: 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.

Read the article for more details: 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.

Read the article for more details: 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.

Read the article for more details: 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.

Read the article for more details: 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.

Read the article for more details: 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.

Read the article for more details: 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.

Read the article for more details: 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 2025 changes means for business planning in 2026

Across 2025, the dominant pattern is clear: Poland is accelerating digital tax administration (The National e-Invoicing System (KSeF) in Poland + expanded JPK reporting), tightening formal requirements in cross-border taxation (WHT and PCC jurisprudence), and increasing compliance reach into HR and supply chains (pay transparency, foreign workers, EUDR). For 2026, the winning approach is early operational implementation—systems, procedures, and accountability—so that legal changes do not translate into business disruption.

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

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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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