Introduction

Poland’s economic growth in recent years has made it an increasingly attractive destination for foreign investors and operational businesses. Simultaneously with this development, the Polish tax system is undergoing one of the most significant reforms in recent years, which affects both personal and corporate income taxpayers. One of the more important recent developments is the introduction of the mandatory e-invoicing system (KSeF), which will have an effect not only on invoicing but also on legal and cash-flow matters for businesses operating in Poland. In addition, Poland is undertaking extensive measures to digitise tax settlements and combat aggressive tax optimisation.

This chapter of the guide presents key changes in the Polish taxation system as of 2026 and for upcoming years.

Key Issues

National e-Invoicing System (KSeF)

One of the more revolutionary changes for 2026 is undoubtedly the final introduction of the mandatory use of the National e-Invoicing System (KSeF) for all businesses operating in Poland.

According to the assumptions of the ViDA (VAT in the Digital Age) project, the obligation to introduce e-invoicing mechanisms will ultimately apply to all European Union countries. However, member states are required to take action in this area gradually. According to current plans, e-invoicing will only become mandatory for intra-EU transactions from 1 July 2030, and for domestic transactions from 1 January 2035. Poland can therefore be described, alongside Italy and Belgium, as one of the European pioneers in the introduction of mandatory e-invoicing.

Coming from ViDA, KSeF is an IT platform designed for the issuance, receipt and storage of structured invoices. In practice, subject to limited exceptions, the introduction of KSeF means that paper and traditional electronic invoices will be phased out in favour of structured invoices issued and received through the unified electronic system.

It is worth noting that KSeF has been in operation since 1 January 2022 as a voluntary solution. However, use of the electronic invoicing system was not popular among taxpayers, and its practical application was limited. This will now change due to the system becoming obligatory.

Key dates

As a result of various factors (including technical and security issues), the date of entry into force of mandatory KSeF in Poland has been postponed several times. In the calendar of changes related to mandatory e-invoicing, two key dates should be noted:

• from 1 February 2026, KSeF became mandatory for large taxpayers with a sales value for 2024 exceeding PLN200 million (approximately EUR46 million) including tax; and
• from 1 April 2026, it will become mandatory for other businesses (including sole traders and small and medium-sized entrepreneurs). An exception is made for the smallest firms, whose invoice-documented sales do not exceed PLN10,000 (approximately EUR2,300) per month. For such entrepreneurs, KSeF will become mandatory on 1 January 2027.

Entities considering expanding their business and entering into the Polish market should familiarise themselves with the rules governing e-invoicing, as it is becoming a reality and part of everyday economic life.

Structured invoices

A key concept from the perspective of operating in the new reality of e-invoicing is the “structured invoice”. According to the new law, this is an invoice issued using KSeF, always together with the identification number assigned to that invoice. Importantly, a structured invoice is a set of digital data in electronic xml format. This format enables proper reading and processing of the data contained in the document. A structured invoice is not the same as an electronic invoice, which is understood to mean an invoice in electronic form issued and received in any electronic format.

Due to the introduction of mandatory invoicing under KSeF, many previously common practices in VAT and income tax settlements have changed – eg, the rules for correcting invoices, which are now much more rigorous.

Issuing invoices in KSeF is now the rule. However, regulations provide for certain exceptions to the requirement to issue structured invoices. This obligation will not apply, inter alia, to:

• issuing invoices by a taxpayer who does not have a registered office or a permanent place of business in Poland; and
• issuing invoices to a purchaser of goods or services who is a natural person and does not conduct business activity.

Advantages of KSeF

According to the assumptions of the Polish Ministry of Finance, the introduction of the mandatory KSeF is expected to bring a number of benefits – both to taxpayers and to the Polish tax administration. Its advantages are supposed to include, above all:

• no need to print documents and enter them manually into systems;
• acceleration of accounting processes;
• increased speed of data exchange in contacts between contractors (an issued invoice is made available to the recipient practically in real time);
• no need to archive invoices – they will be stored in KSeF for a period of ten years from the end of the year in which they were issued (this may be particularly important from the perspective of large entities);
• shortening the basic VAT refund period from 60 to 40 days; and
• reducing VAT fraud.

Current issues

However, the Polish e-invoicing system is not without its flaws and its introduction to the Polish tax system was not without obstacles. The biggest current issues with KSeF include:

• high risk of system failure and the need to introduce effective alternative mechanisms to issue and receive invoices;
• high penalties for non-compliance with KSeF requirements – in some situations, the penalty for failure to comply with e-invoicing obligations may be as high as 100% of the tax amount as indicated on the invoice; and
• the risk of data leaks from KSeF and cyber-attacks.

Digitalisation of record-keeping obligations

As part of the introduction of a fully digital tax settlements system in Poland, changes are also continuing with regards to the methods of keeping records and reporting them to the tax authorities. This primarily concerns the further extension to new taxpayers of the obligation to keep accounting records using computer software and to transfer the resulting data in an electronic form – corresponding to the logical structure specified by the Minister of Finance (JPK CIT). Entities covered by this obligation are required to send structured data to the tax office once a year, by the deadline for submitting the CIT-8 tax return (usually by end of March of the year following the tax year).

The obligation, as of 2025, concerns tax capital groups and the largest entities with revenues exceeding EUR50 million. From 2026 it also applies to CIT taxpayers, partnerships and PIT taxpayers who maintain accounting records and are required to submit JPK_V7 records and declarations on a monthly basis. It should be noted that in 2027 this obligation will be further extended to additional groups of entities.

However, digitalisation does not only apply to entities that keep accounting records. From 2026, active VAT taxpayers who submit JPK_V7M records and declarations on a monthly basis are also required to keep electronic revenue and expense ledgers using computer software. After the end of a given tax year, the taxpayer must send the aforementioned revenue and expense ledger in the appropriate format to the relevant head of the tax office by 30 April of the following year. In 2027, this obligation will be extended to other entities.

This reporting system provides tax authorities with broad access to a wide range of accounting and tax data for an extensive group of taxpayers. Due to the structurisation of data, the Polish tax administration is equipped with highly effective tools for precise selection of entities for tax audits and inspections. The effectiveness of tax audits should also increase within the new framework.

Combating aggressive tax optimisation

In 2025, two new institutions were established to combat aggressive tax optimisation – especially in the area of income tax. These are:

• the Team for Combating Aggressive Tax Planning in Corporate Income Tax (Zespół ds. zwalczania agresywnego planowania podatkowego w podatku dochodowym od osób prawnych), established by the Ministry of Finance; and
• the Competence Centre of the National Tax Administration in Krakow (Centrum Kompetencyjne Krajowej Administracji Skarbowej w Krakowie).

These specialised institutions are primarily focused on tax settlements of large entities, often having extensive international structures, which evade their tax obligations, in particular in relation to corporate income tax. Their establishment is a response to the growing issue of under-reporting income within the scope of transfer pricing.

The Team operating at the Ministry of Finance focuses, among other things, on the issue of transfer pricing as an instrument that is often used to artificially inflate or understate prices in transactions between related companies from different countries. The Team investigates cases where lower income is reported in Poland, resulting in lower tax payments to the Polish tax authorities.

On the other hand, the Competence Centre is responsible for detecting and neutralising aggressive tax optimisation schemes. Its tasks primarily include:

• analysing information about such schemes;
• collecting and processing data from the JPK CIT and KSeF systems; and
• preparing proposals for legal changes that would prevent the use of aggressive tax strategies.

The ongoing digitalisation of tax settlements and the establishment of the aforementioned institutions should be seen as a signal, particularly for large entities, to ensure correctness of their settlements and not to neglect their transfer pricing obligations, as this is an area to which the Polish tax administration pays particular attention. In conjunction with the introduction of the mandatory KSeF and the gradual expansion of JPK CIT obligations, possible irregularities on the part of taxpayers may be quite easily identified by the tax authorities.

Amendments to the taxation of financial institutions

Following legislative trends in some European countries, Poland has also decided to introduce changes in the taxation of financial institutions from 2026, significantly complicating the regulations in this area. The changes primarily affect banks and credit institutions, but also co-operative savings and credit unions (spółdzielcze kasy oszczędnościowo-kredytowe).

For CIT purposes, instead of the standard 19% rate previously applied, different rates will apply depending on the type of financial institution. Ultimately, they will be:

• 23% – for banks (domestic and foreign) and credit institutions, with certain exceptions;
• 21% – for co-operative banks (banki spółdzielcze) and co-operative savings and credit unions; and
• 11% – for the above-mentioned banks and institutions (with certain exceptions) whose revenues in the tax year did not exceed the equivalent of EUR2 million.

It should be noted that these are target rates. Until 2028, there will be a transition period during which higher rates will apply, in some cases reaching up to 30%.

The changes in rates will also be visible in the tax on certain financial institutions. From 2027, some taxpayers will be taxed at a new, reduced rate of 0.0329%, which will further decrease to 0.0293% in 2028.

Additional matters

Apart from the implementation of KSeF, the ongoing digitalisation process, combating aggressive tax optimisation, and changes in the taxation of financial institutions, there are also other areas that should attract taxpayers’ attention in 2026.

Higher VAT exemption limit

In 2026, an amendment came into force providing for an increase in the VAT exemption limit. Previously, the threshold was PLN200,000 (approximately EUR47,000) and it has now been raised to PLN240,000 (approximately EUR55,000). This means that a greater number of entrepreneurs with their place of business in Poland will be able to operate without charging VAT and without performing the record-keeping obligations applicable to active VAT taxpayers.

General partnership (spółka jawna) as a tax transparent entity

Aa a rule, a general partnership is not a CIT taxpayer. In some situations, however, it may become one. Previously, to avoid CIT taxation, partnerships had to submit, before the start of each financial year, information on CIT and PIT taxpayers entitled to share in the profits, even if there were no changes in the composition of partners. From 1 January 2026, administrative obligations have been reduced by abolishing the requirement to provide annual information on the composition of partners if the information previously submitted remains valid.

Extension of the principle of in dubio pro tributario

Recently, the principle of in dubio pro tributario has been extended. In tax proceedings initiated ex officio, subject to certain exceptions, doubts regarding the facts that cannot be removed are resolved in favour of the party. Previously, only ambiguities regarding legal provisions had to be resolved in favour of the taxpayer.

Summary

The Polish tax system is facing major changes related to e-invoicing and the digitalisation of various compliance and tax-related processes. This requires entities operating on the Polish market to be flexible, proactive and able to adapt quickly. The new instruments available to the tax administration in Poland make it extremely important to comply with all tax settlement regulations. Tax authorities have a range of options (which will only expand in the coming years) that allow them to identify even minor irregularities, select entities for inspection more accurately, and enforce tax obligations more effectively. The tax administration is responding to aggressive optimisation attempts by creating specialised units, which should be of particular interest to large cross-border entities with complex structures.

Poland is currently one of the biggest economies in the world and, as such, is an interesting destination for business development. However, when planning business operations in the jurisdiction, it is important to bear in mind the current digital revolution in tax settlements.