Why are fiscal penalties rising from January 2027?
The mechanism is simple, although its effects can be severe. The Fiscal Penal Code does not use fixed fine amounts - it ties them to the level of the minimum wage. Every increase in the minimum wage therefore automatically raises the limits of financial penalties for fiscal misdemeanours and fiscal offences. This is the result of a single government decision, which set the minimum wage for 2027 at PLN 4,950 gross.
For business owners, accountants and tax advisers, this means the need to reassess risk. An error in a return, a late filing or irregularities in records - any of these events may cost more from the new year than before. It is therefore worth examining carefully how the individual thresholds and rates will change.
Importantly, the increase in penalties applies both to minor fiscal misdemeanours and to serious offences. Below we present a detailed summary of the new limits applicable from 1 January 2027.
New fine limits for fiscal misdemeanours
A fiscal misdemeanour is an act of lesser gravity - for example, late filing of a tax return, minor errors in sales records or failure to perform certain tax obligations. The Fiscal Penal Code provides that a fine for a fiscal misdemeanour may range from one tenth to twenty times the minimum wage.
With a minimum wage of PLN 4,950, the range of the fine for a fiscal misdemeanour in 2027 will be as follows:
- Minimum fine - PLN 495 (currently PLN 480.60)
- Maximum fine - PLN 99,000 (currently PLN 96,120)
The upper limit of penalty notices (mandates) imposed, among others, by tax officials will also change. Their maximum value will rise to PLN 24,750, which is an increase of around PLN 700 compared with 2026. A penalty notice is a simplified procedure - it does not require court proceedings, but the amount an official can impose is becoming increasingly significant.
It is worth remembering that even seemingly minor formal shortcomings can result in a financial penalty. Regularly verifying tax obligations and the timeliness of filings is the simplest way to avoid unpleasant consequences.
Fiscal offences - fines reaching tens of millions of zloty
In the case of fiscal offences, the scale of penalties is incomparably higher. The Fiscal Penal Code applies a system of daily rates rather than a one-off amount. The court determines both the number of rates and the amount of a single rate - taking into account the offender's financial situation, income and personal circumstances.
From 2027, the key values will be as follows:
- Single daily rate - from PLN 165 to PLN 66,000
- Maximum number of daily rates - 720
- Maximum fine (720 × PLN 66,000) - PLN 47,520,000
- Extraordinary aggravation of the penalty - up to 1,080 daily rates, giving an upper limit of PLN 71,280,000
The amount of PLN 71.28 million is more than PLN 2 million higher than the equivalent limit in 2026. Extraordinary aggravation of the penalty is applied in special circumstances provided for by the regulations - for example, in cases of repeat fiscal offending or acting within an organised group.
Such high fines naturally apply to the most serious cases, but the daily rate mechanism itself means that even an "average" fiscal offence may carry a penalty running into hundreds of thousands of zloty. For companies operating on a large scale, the risk is all the more real.
Threshold between a misdemeanour and a fiscal offence - the PLN 24,750 limit
One of the key concepts in fiscal criminal law is the threshold between a misdemeanour and an offence. The classification of an act is often determined by the amount of the public-law liability that has been reduced or put at risk of reduction. In 2027, this limit will be PLN 24,750, which is five times the minimum wage.
What does this mean in practice? If the amount of the shortfall does not exceed PLN 24,750, the act is, as a rule, classified as a fiscal misdemeanour. Above this threshold, it may potentially be a fiscal offence, with far-reaching consequences, including an entry in the National Criminal Register.
However, it must be stressed that exceeding the threshold does not automatically mean the act is classified as an offence. The provisions relating to the specific type of violation also matter. Some acts - regardless of the amount - may constitute only misdemeanours or only offences.
The concept of "great value" in 2027
The Fiscal Penal Code also uses the concept of "great value", which affects the tightening of liability. In 2027, an amount exceeding PLN 4,950,000, that is one thousand times the minimum wage, will be regarded as great value. Acts involving amounts of this size carry the harshest sanctions provided for in the Code.
How can you reduce fiscal criminal risk in your company?
Rising penalties are a signal to review internal tax and accounting procedures. Even an unintentional error can lead to fiscal criminal proceedings being initiated, and the level of potential fines is rising year after year. Here are the key areas worth paying attention to:
- Timely filing of returns - delays are one of the most common causes of proceedings for fiscal misdemeanours
- Accuracy of records - errors in VAT sales records can result in both penalties and the denial of the right to deduct
- Compliance of tax structures with the regulations - using tax optimisation requires careful planning and, as a rule, reliance on individual tax rulings
- Transfer pricing documentation - irregularities in settlements between related entities can generate significant shortfalls
- Implementation of KSeF (the National e-Invoicing System) and new reporting obligations - the coming years bring additional requirements, and failure to meet them is also subject to sanctions
Professional accounting and tax services are not just a convenience, but above all an element of risk management. With a properly planned structure and ongoing oversight of filings, the likelihood of making a costly error falls significantly. This applies both to sole proprietorships and to companies with a complex holding structure.
Need support? Take advantage of a free consultation
The increase in fiscal penalties from 2027 is a good moment to take a look at your tax filings and assess whether your company is adequately protected against fiscal criminal risk. Even a minor oversight - a late return, an error in records or an incorrectly applied VAT rate - may cost more from the new year than ever before.
Global Accounting has for over 10 years supported business owners in Poland with full accounting services, VAT, CIT and PIT returns, and the implementation of lawful tax structures. The team has carried out over 2,000 consultations and helped clients generate more than PLN 20 million in tax savings in total - always based on individual analysis and the regulations in force.
If you want to make sure your filings are correct, or you are planning to reorganise your business in a way that minimises risk - book a free consultation (the first 15 minutes free). Call +48 505 684 412 or write to [email protected].
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