A revolution in the lump-sum tax - what is the Ministry of Finance planning?
Lump-sum tax on recorded revenue (ryczałt) is a simplified form of taxation that has gained huge popularity among Polish entrepreneurs in recent years. According to Ministry of Finance data, around 951,000 taxpayers running non-agricultural businesses currently use this form of taxation. The appeal of ryczałt has come from its low tax rates, a flat-rate health insurance contribution, and a mechanism that allows even very high revenue to be taxed favourably.
Now, however, the Ministry of Finance intends to change the rules of the game dramatically. The published assumptions for the draft amendment contain two key proposals that are due to take effect from 1 January 2027. Notably, one of them - the new, higher rate of ryczałt - was not mentioned during the official presentation of the tax changes. Entrepreneurs should already be analysing how the planned reforms will affect their tax position and considering whether to change their form of taxation.
Below we discuss in detail the scope of the proposed changes, their practical consequences and the group of taxpayers who will be hit hardest. This knowledge is essential for making informed business decisions in the coming months.
Two key changes - a lower limit and a new 17% rate
The Ministry of Finance proposes two fundamental changes to the rules for using lump-sum tax on recorded revenue. Both changes are to apply to revenue earned from 1 January 2027 and will significantly affect how hundreds of thousands of entrepreneurs account for tax.
Lowering the revenue limit for eligibility for ryczałt
The first change is a drastic reduction of the revenue limit that determines the right to choose ryczałt. The current limit is €2 million (approx. PLN 8.5 million) and is to be cut to just €250,000 (approx. PLN 1 million). This means that in 2027 only a taxpayer whose revenue in 2026 did not exceed this new, much lower threshold will be able to choose ryczałt.
Introducing a 17% rate on excess revenue
The second, equally important change is the introduction of a new ryczałt rate of 17%, which will apply to revenue earned during the year in excess of €300,000 (approx. PLN 1.3 million). In practice, this means that an entrepreneur who exceeds this threshold during the year will pay 17% tax on every zloty above the limit - regardless of the existing, lower ryczałt rate (e.g. 8.5% or 12%).
It is worth stressing that the €250,000 limit refers to revenue from the previous year (the condition for entering ryczałt), while the €300,000 limit applies to revenue in the current tax year (the threshold for the higher rate). This distinction is crucial for tax planning.
Who will be affected and what will the financial consequences be?
According to Ministry of Finance data for 2024, the changes will affect around 43,000 entrepreneurs whose revenue exceeded €250,000. Of these, around 400 taxpayers earned revenue above €2 million, and the record-holders reported revenue of as much as PLN 100 million. The total revenue of this group came to PLN 102 billion.
The Ministry justifies the changes by the need to make the tax and contribution system fairer. It points to several significant inequalities in the current system:
- Ryczałt taxpayers do not pay the solidarity levy on income above PLN 1 million, from which taxpayers on general rules cannot exempt themselves
- They benefit from a preferential, flat-rate health insurance contribution - on revenue above PLN 300,000 they pay a fixed contribution of just PLN 1,495.04 per month
- An entrepreneur with revenue of €250,000 pays the same health insurance contribution as one with revenue of PLN 100 million
- As a result, people with very high revenue bear lower tax and contribution burdens than employees who earn many times less
More recent data - for 2025 (as of August 2026) - indicate that the number of taxpayers with revenue above PLN 1 million has already risen to 54,000 people, which points to the growing scale of the phenomenon and may further motivate the legislator to implement the changes quickly.
Practical consequences for entrepreneurs - how to prepare?
The planned changes to ryczałt bring a number of practical consequences that require advance preparation. Tax experts, including tax adviser Radosław Kowalski, point to several key problems that may affect entrepreneurs.
The phenomenon of slowing down economic activity
Introducing the €300,000 threshold for the higher ryczałt rate may deepen the phenomenon of slowing down activity before the end of the year. Entrepreneurs approaching the limit may deliberately restrict their activity, because crossing the threshold will cause a sudden jump in tax burdens. This phenomenon is already known in the context of the health insurance contribution and, in the experts' view, the new rules may intensify it further.
The need to analyse the cost-effectiveness of the form of taxation
Entrepreneurs whose revenue is close to the new limits should already carry out a detailed comparative analysis of the different forms of taxation. In many cases, switching to the flat-rate tax (19%) or general rules (tax scale) may prove more beneficial than staying on ryczałt with the new 17% rate on the excess. The ratio of deductible costs to total revenue will be of key importance.
It is worth remembering that the changes are assumptions for a draft act, which means their final shape may still be modified during the legislative process. Nevertheless, entrepreneurs should take these proposals seriously and consult tax advisers about their situation in good time.
What should entrepreneurs do now?
Whether or not the planned changes take effect in the proposed form, entrepreneurs who use lump-sum tax on recorded revenue should take concrete preparatory steps. Here are the most important actions to consider:
- Analyse your revenue for recent years and check whether it exceeds the new €250,000 limit
- Compare the tax burdens under ryczałt (taking into account the new 17% rate) with other forms of taxation
- Consult a tax adviser or a law firm specialising in tax law about your situation
- Follow the legislative process - the final shape of the rules may differ from the assumptions
- Consider restructuring your business if changing the form of taxation proves more beneficial
The changes to ryczałt are one element of a broader reform of the tax system, which aims to increase budget revenue. For entrepreneurs, this means the need to actively manage their tax burdens and continually adjust their business strategy to a changing legal environment.
Do you need an individual analysis of how the planned changes will affect your business? Contact our firm - our tax law specialists will help you choose the optimal form of taxation and prepare for the coming changes. Do not wait until the last minute - the sooner you start planning, the better you will protect your interests.
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