Changes in VAT 2026, planned amendments to regulations

The new regulations combine two goals: deregulation and tightening the tax system. By eliminating unnecessary obligations and clarifying regulations, running a business is expected to become simpler while simultaneously reducing the risk of VAT evasion.

From this article you will learn, among other things:

• What changes will there be to make it easier to do business?
• Which obligations imposed on taxpayers will be eliminated?
• What clarifying changes does the legislator envisage?

What changes will there be to make it easier to do business?

According to data from the Central Statistical Office (GUS), there were 2,875,994 active enterprises in Poland in the third quarter of 2025. The increase in the number of active businesses is observed primarily among microenterprises, with a negative trend observed in the remaining groups (small, medium, and large companies). Businesses in Poland are grappling not only with rapidly changing regulations but also with a growing number of various statutory obligations. The solutions proposed by the legislator in this draft are intended to address this issue.

1. Creation of tax liability for deliveries

One of the key solutions is to standardize the tax point in specific situations, such as the delivery of goods or services performed upon an order from a public authority or by operation of law in exchange for compensation. The amendment introduces consistent rules in this regard, which will cover both the transfer of ownership of goods and the provision of services commissioned by entities acting on behalf of public authorities.

2. VAT warehouses

A key element of the reform is the introduction of the VAT warehouse, which is expected to significantly simplify tax settlement and collection for entities participating in international trade in goods. Therefore, a modification to Article 29a, Section 1 of the VAT Act is planned, which will exclude the application of the general rules for determining the tax base at the time of removal of goods from the warehouse. In such cases, the tax base will be determined according to new, dedicated rules provided for in the proposed Article 138x of the Act.

3. List of VAT payers and e-check-in at terminals

Responding to business demands for transparency in settlements, the bill also proposes changes to the list of VAT payers. Amendments to Article 96b, Section 2 of the Act will enable verification of a contractor's status as of a specific date in the past, covering a period of up to five years back from the year in which the verification is conducted. Furthermore, the reform includes improvements in the tourism and trade sectors by introducing provisions enabling e-clearance directly at TAX FREE terminals.

See also: VAT. Split payment mandatory until February 28, 2028.

Which obligations imposed on taxpayers will be eliminated?

The proposed changes focus on deregulation and removing unnecessary administrative burdens that have so far involved both entrepreneurs and tax office employees.

1. Elimination of the obligation to submit separate information on physical inventory

One of the key improvements is the elimination of the requirement to submit separate information on physical inventory. Currently, this data, including the amount of tax due on goods covered by the inventory, is already reported as part of the Standard Audit File (JPK_VAT). Because this information is duplicated in both documents, the legislator deemed maintaining a separate report unnecessary, providing tax authorities with access to the necessary amounts directly from the JPK_VAT.

2. Elimination of the obligation to disclose the tax base in the case of the purchase of goods and services exempt from tax

Another significant step towards simplifying settlements involves eliminating the obligation to report the taxable amount for the purchase of tax-exempt goods and services. Previously, taxpayers were required to report such transactions (e.g., importing services from a foreign entity benefiting from the exemption), even though this did not result in the calculation of output tax. Following the entry into force of the new regulations, such acquisitions will no longer need to be included in JPK_VAT, VAT-8, or VAT-9M declarations. This change will apply to both services exempted subjectively (e.g., under the SME procedure) and objectively, pursuant to Article 43, Section 1 of the VAT Act.

3. Abolition of the obligation to pay VAT on intra-Community acquisitions of means of transport

The reform also provides for the repeal of Article 103(4), which eliminates the obligation to pay VAT within 14 days of the intra-Community acquisition of a means of transport. This change is intended to clarify and deregulate the terms of the VAT return and applies to taxpayers who already settle intra-Community acquisition in their standard periodic declarations. This will align the payment process with the general principles for settling EU transactions, which will positively impact businesses' financial liquidity.

Also read: Recovering VAT interest on intra-Community acquisitions

What clarifying changes does the legislator envisage?

Below we present a short summary of the proposed clarification and streamlining changes, which are intended to eliminate interpretation doubts in tax regulations:

Corrections in the area of commodity and energy trade

• In order to adapt the law to the development of electromobility, the Ministry proposes to change the rules for taxing energy supplied outside the electricity system. By removing the link with the Energy Law, VAT regulations will become fully compliant with EU requirements, regardless of the energy distribution channel.
• The rules for settling VAT on packaging covered by the deposit-refund system have been tightened and clarified.
• The project involves modifying the regulations regarding import procedures, adapting them to current legal requirements.
• Article 120 of the VAT Act introduces changes to the specific procedures for taxing works of art, antiques and collectors' items.

Changes in limits and reliefs

• The methodology for calculating a taxpayer's turnover, which determines eligibility for the VAT exemption, has been clarified.

Also read: Important change for businesses: new VAT exemption limit from 2026.

• The amendment clarifies the provisions allowing for the recovery of tax on bad debts, which is intended to facilitate the use of this institution in practice. The bad debt relief mechanism for entities that are not active VAT payers has been clarified. The new regulations stipulate that corrections are possible from the receipt of payment (the moment the tax liability arises) to the expiry of 180 days from the date of performance. This change eliminates doubts regarding the earliest and latest deadlines for settling the relief.

Rate and tax identification updates

• The wording of the regulations on disinfectants, to which a reduced VAT rate of 8% applies, has been updated.
• Significant changes are planned in the Act on the principles of recording and identifying taxpayers, including:
  • New rules regarding the procedure for repealing the Tax Identification Number (NIP), the requirement to issue a formal administrative decision has been abandoned in favour of a material and technical action.
  • Editorial and ordering amendments to the structure of the Tax Identification Number Act - both the list of grounds for repealing the Tax Identification Number and the list of circumstances allowing its restoration have been expanded.

When will the new regulations come into force?

According to the draft, the effective date of the Act is set for 1 July 2026. However, the draft provides for a number of exceptions for which later effective dates are specified:

From 1 January 2027, the following regulations will come into force:

• new rules regarding the institution of repealing the NIP (extending the deadline is to enable economic participants to prepare for the changes);
• a new method of calculating turnover for the purposes of subjective exemption in VAT;
• introducing the institution of VAT warehousing;
• elimination of the obligation to pay VAT within 14 days of the intra-Community acquisition of a means of transport;
• new obligations regarding the disposal of cash registers and the servicing of virtual cash registers.

From 1 July 2027, regulations will come into force regarding:

• prohibition of replacing fiscal memory in cash registers with electronic copy recording.

From 1 July 2028, the following regulations will come into force:

• implementation of the "TAX FREE e-clearance" system, enabling travellers to independently and voluntarily declare the export of goods using IT tools provided by the National Revenue Administration.

Changing regulations are a challenge, let's overcome them together. Prepare now for the changes coming into effect on July 1, 2026, and ensure your company receives expert support in CIT, PIT, and VAT.

Check out our tax advisory services in Poland