Change in the implementation deadline for mandatory e-Delivery in Poland

The Ministry of Digital Affairs has announced a postponement of the mandatory requirement for having an e-Delivery mailbox. The official announcement was published by the Minister of Digital Affairs in the Journal of Laws.

The new implementation date for e-Delivery is January 1, 2025.

The postponement will allow for amendments to the Act on Deliveries and other laws, introducing a transitional period for implementing e-Delivery.

Implementing e-Delivery as a new way of handling correspondence is a significant technical and organizational challenge, especially for public entities. Analysis by the Ministry of Digital Affairs shows that only 30% of the required public entities have applied for an electronic delivery address.

Therefore, it was decided that to effectively implement e-Delivery, a transitional period until December 31, 2025, is necessary. During this period, public entities will gradually adapt to the new system.

During the transitional period, deliveries via postal operator, the Electronic Platform of Public Administration Services (ePUAP), and other sector-specific systems will be equivalent to e-Delivery.

What is e-Delivery?

E-Delivery is the electronic equivalent of a registered letter with acknowledgment of receipt, compliant with the EU eIDAS regulation and the Act on Electronic Deliveries. They hold the same legal value as traditional registered mail with acknowledgment of receipt. Finally, all public entities, businesses, and trusted professions will be required to have an electronic delivery address and conduct correspondence through e-Delivery.

Who is required to use e-Delivery?

The requirement to use e-Delivery will apply to all public entities and companies registered in the National Court Register (KRS) and the Central Registration and Information on Business (CEiDG).

Schedule for Implementing Mandatory e-Delivery

The obligation to introduce e-delivery for non-public entities will concern:

From January 1, 2025:

• Trusted professions: lawyers, legal advisors, tax advisors, restructuring advisors, patent attorneys, notaries.
• Entities registering in the Polish corporate register (KRS) from January 1, 2025.
• Entities applying for entry into CEiDG (Polish register for entrepreneurs/sole proprietorships).

From April 1, 2025:

• Entities registered in KRS before January 1, 2025.

From July 1, 2025:

• Entities registered in CEiDG before December 31, 2024 – in case of changes in the entry after June 30, 2025.

From October 1, 2026:

• Entities registered in CEiDG before December 31, 2024.

The obligation to introduce e-delivery for public entities will include:

From January 1, 2025:

• Government administration bodies and their budgetary units.
• Other public authorities and budgetary units.
• Social Insurance Institution (ZUS) and its managed funds, Agricultural Social Insurance Fund (KRUS).
• National Health Fund (NFZ).
• Executive agencies, budgetary economy institutions, state special-purpose funds, public healthcare institutions, public universities, the Polish Academy of Sciences, cultural institutions, and other public entities established by separate laws to perform public tasks.
• Other public entities.

From October 1, 2029:

• Local government units and their associations, metropolitan unions, and local government budgetary institutions – for the hybrid public service.
• Courts, tribunals, bailiffs, prosecutors, law enforcement, and the Prison Service.

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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