Revolut in Poland - why do users feel safe?
Revolut has gained enormous popularity among Polish users. According to the latest app data, more than 5 million customers in Poland now use it, making our country one of the key markets for this fintech giant. Attractive exchange rates, instant international transfers and convenient multi-currency cards mean that many Poles treat Revolut as their main bank account.
At the same time, a dangerous belief has grown among users that a Revolut account is invisible to the Polish tax authorities. This myth has historical roots - before Brexit, Revolut operated as a British financial institution, which may have suggested that Polish tax authorities had no access to it. After the United Kingdom left the European Union, some customers became convinced, wrongly, that the fintech operates entirely outside the reach of Polish law.
In reality, the legal position is quite different. The world of finance is becoming ever more transparent, and international exchange of tax information covers practically all legitimate financial institutions in Europe. Ignoring this fact can lead to serious legal and financial consequences.
The Lithuanian banking licence - the key to understanding the legal position
The key fact that debunks the myth of Revolut's invisibility is the change in its regulatory status. Since 2022, Revolut has operated under a Lithuanian banking licence issued by the European Central Bank. This means that Revolut Bank UAB is fully subject to EU banking regulations, including the rules on automatic exchange of tax information.
In practice, this means that Revolut must comply with the DAC Directive (Directive on Administrative Cooperation), which requires financial institutions in EU countries to report data on tax residents of other Member States. The Lithuanian tax authorities receive annual reports from Revolut on Polish residents and then pass this information to the National Revenue Administration (KAS) in Poland.
It is worth stressing that this mechanism works automatically - the Polish tax authorities do not need to submit individual requests to obtain basic information about Polish citizens' Revolut accounts. The system of automatic exchange of tax information, based on the CRS (Common Reporting Standard), covers data such as the account balance, interest income and investment gains.
What data about your Revolut account can the tax authorities obtain?
The scope of information that the Polish Tax Office can access is much wider than most users think. Two modes of obtaining data should be distinguished: automatic exchange of information and individual requests where irregularities are suspected.
Data transmitted automatically (annually)
Under the standard exchange of tax information, the Polish tax authorities may receive the following data:
- Confirmation that you hold an account with Revolut Bank UAB
- The account balance at the end of the calendar year
- Interest income accrued on the account
- Investment gains - including from trading in cryptocurrencies and shares available in the app
- Dividends and other capital income
Data available on individual request
Where a tax audit or clarification proceedings are opened, the tax authorities may request much more detailed information. This includes the full transaction history, data on currency conversions and even information about counterparties. Revolut, as a licensed bank in the EU, has a legal obligation to respond to such a request - refusing to cooperate is not an option.
It should be noted, however, that the tax authorities do not have permanent, direct real-time access to Revolut accounts. Day-to-day activity - ordinary card payments, currency conversions or transfers between your own accounts - is not monitored on an ongoing basis.
Revolut, the OGNIVO system and enforcement by bailiffs
A separate issue worth raising from a legal perspective is enforcement by bailiffs against Revolut accounts. The OGNIVO system is an electronic tool for exchanging information between banks, credit unions (SKOK) and enforcement authorities in Poland. Court bailiffs use it to quickly locate debtors' bank accounts.
Revolut, as a foreign financial institution based in Lithuania, is not currently connected to the OGNIVO system. In practice, this means that a bailiff cannot identify and seize funds in a Revolut account within seconds, as they can with Polish banks. However, this does not mean full protection from enforcement.
A bailiff can direct an enforcement seizure straight to Revolut Bank UAB in Lithuania, using the European Account Preservation Order (EU Regulation No 655/2014). This procedure is longer and more complicated, but it is entirely lawful and effective. Relying on the idea that funds in Revolut are out of creditors' reach is therefore a serious mistake.
Legal consequences of concealing income in Revolut
Attempting to conceal income by holding it in a Revolut account can lead to serious legal and tax consequences. Polish tax law clearly states that a Polish tax resident is liable to tax on all of their income, regardless of where it is held.
People who do not declare income held in foreign accounts expose themselves to:
- Audit proceedings by the National Revenue Administration (KAS)
- Assessment of unpaid tax together with late-payment interest
- A fine under the Fiscal Penal Code - up to 720 daily rates
- Fiscal criminal liability for tax evasion (Art. 54 of the Fiscal Penal Code)
- Loss of the option to rely on effective repentance (czynny żal) if the irregularities are detected by the tax authority
Particularly risky from the tax authorities' perspective are regular receipts that look like remuneration and are not reported anywhere, large one-off sums without a documented source, and unreported cryptocurrency gains and investments made through the Revolut app.
What should Revolut users know? Legal summary
Using Revolut is entirely legal and safe - provided that the user properly settles their tax affairs with the Polish tax authorities. Revolut is not a tool for concealing income, and the belief that this account is invisible to the Polish Tax Office is a harmful myth that can lead to serious legal problems.
Key facts to remember: Revolut operates under a Lithuanian licence and is subject to EU regulations, automatic exchange of tax information covers the data of Polish residents, the tax authorities can obtain detailed account data in the event of an audit, and the lack of a connection to the OGNIVO system does not protect against enforcement by bailiffs.
If you have doubts about the correct reporting of income earned or held through Revolut, contact our firm. Our tax law specialists will help you assess your situation, avoid mistakes and - where necessary - use effective repentance or voluntary disclosure before the tax authorities come knocking at your door.
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