Significant changes in the requirement to record sales using cash registers
Dear Sir or Madam,
In the light of the latest draft bill of the Minister of Finance on exemptions from the obligation to keep records of sales using cash registers, which was published on the website of the Government Legislation Centre on 16 August this year, we would like to inform you of the main changes planned for 2025-2026. Some of the planned changes will come into force on 1 January 2026.
Termination of exemptions for self-service sales
One of the most significant changes resulting from the Bill (as published) is the narrowing of the scope of the exemption from record keeping for self-service sales. Previously, taxpayers who sold through customer-operated automatic selling devices (e.g. vending machines), ticket machines or other automatic devices were exempt from the obligation to use cash registers, provided that their sales did not include goods or services excluded from this exemption. The new rules remove these exemptions, with the exception of sales of public transport services.
From 1 January 2026, traders selling goods or services using self-service devices (e.g. vending machines, ticket machines) will be obliged to record transactions using cash registers. The obligation will also extend to parking services, regardless of the method of payment.
According to the explanatory memorandum to the bill, this change is due to the need to seal the sales registration system and to eliminate non-compliance reported by the control authorities.
Exemption extended until the end of 2025
It should be noted that taxpayers who already benefit from the exemption for self-service sales (vending machines, ticket machines) and for parking services will be exempt from the obligation to keep records of sales via cash registers until the end of 2025. This is important from a business point of view as it gives them more time to prepare for the new requirements.
Extended list of goods and services that are subject to mandatory fiscalisation
The bill extends the list of goods and services that must be recorded by means of cash registers. In addition to the sale of goods from vending machines and ticket machines, the recording requirement will also apply to (without limitation):
- Products classified under CN 2404 and 8543 40, including but not limited to nicotine-containing products, reconstituted tobacco, electronic cigarettes and other vaporizing devices.
- Hemp (Cannabis) products classified under CN 1211, intended to be smoked or inhaled without combustion.
- Products containing more than 50% ethyl alcohol by volume not intended for human consumption – such as, but not limited to, solvents, disinfectants, paint thinners, de-icing fluids.
Exemptions of new entities
The bill also introduces a new category of taxpayers who will be exempted from the obligation to record sales using cash registers. This applies to taxpayers who use the EU SME scheme and use a tax identification number with the ‘EX’ suffix. The exemption is justified by technological limitations resulting from the incompatibility of Polish cash registers with foreign recording systems.
Limit on the exemption from the use of cash registers
Notwithstanding the new record-keeping requirements, the turnover threshold above which a taxpayer is obliged to use a cash register will remain unchanged. Between 2025 and 2026, the limit will be PLN 20,000 per year, while for new taxpayers it will be set in proportion to the period of their business activity in a given tax year. This limit will apply to both existing and new taxpayers.
Impact on taxpayers’ activities
The planned changes will result in a number of new obligations for entrepreneurs. The requirement to use cash registers for the sale of goods and services that were previously exempt from this requirement means that taxpayers will have to adapt their businesses to the new tax obligations. In particular, the changes include:
- purchasing cash registers suitable for their activities.
- Keeping full records of sales, which includes issuing receipts, keeping cash register reports and accounting for transactions in the VAT JPK system.
- Keeping a close eye on transactions and complying with the new rules to avoid sanctions resulting from inaccuracies in sales records.
Conclusion
The planned changes to the legislation governing the recording of sales at cash registers will have a far-reaching impact on entrepreneurs doing business in Poland. It is a further step in the tightening of fiscal policy and the fight against the VAT gap.
We encourage you to contact our team of professionals. We will help you through the process of adapting to the new tax requirements and aligning your business with the new regulations.
KONTAKT
E: aleksandra.kalinowska@pl.Andersen.com
T: +48 22 690 08 70
M: +48 724 440 693
E: elzbieta.lis@pl.Andersen.com
T: +48 32 731 68 58
M: +48 664 948 038
