New KAS powers from August 2025 - account freezes without warning
August 2025 brought a fundamental change in the relationship between business owners and the National Revenue Administration (KAS). The amendment to the KAS Act came into force almost unnoticed, yet its consequences may be severe for thousands of Polish companies. The previous model of tax inspection - based on notifying the taxpayer in advance that proceedings were being opened - has been significantly curtailed.
Under the new rules, tax officials have gained the right to open an inspection without prior warning to the business owner. What is more, in the course of their activities they can immediately seize the company's bank accounts - both business accounts and the owner's private accounts. All it takes is for the tax office to form a "reasonable suspicion of irregularities" in the tax settlements.
In practice, this means that a business owner may only learn about an inspection once their funds have already been frozen. This puts companies in an extremely difficult position, particularly smaller ones that do not have the financial reserves to survive a period of account blockage.
For many taxpayers this is an unprecedented change - until now, the obligation to give notice of an inspection allowed time to put documentation in order and consult a tax adviser or lawyer. That time buffer has now been practically eliminated.
Artificial intelligence and data exchange - how the tax authority selects companies for inspection
The new KAS inspection powers are only one side of the coin. The other is an advanced analytical infrastructure that allows the tax authorities to identify potential irregularities faster and more effectively than ever before. The Ministry of Finance is deploying systems based on artificial intelligence that analyse and compare data from many sources simultaneously, in real time.
AI algorithms combine information from the National e-Invoicing System (KSeF), banking systems, customs offices and the Social Insurance Institution (ZUS). Any unusual discrepancy - for example, a difference between declared revenue and receipts in bank accounts - can automatically trigger a verification process and, as a result, lead to an inspection and an account freeze.
Online platforms under the tax authority's scrutiny
It is worth stressing that the new EU regulations also cover sales and service platforms. Services such as Allegro, OLX, Booking and Airbnb have been required to collect detailed data on their users' transactions and pass it directly to the tax authorities. This applies both to regular sellers and to people who only occasionally offer goods or services.
This means that even occasional online sales of items, or renting out property on platforms such as Airbnb, may be identified by the system and compared with tax returns. If the data does not match, the risk of an inspection increases dramatically.
Freezing of a business account - consequences for the business
For a business owner, having bank accounts frozen by the tax authority is a scenario that can mean immediate operational paralysis of the company. The effects of a freeze are multi-dimensional and can affect every aspect of running the business. Here are the most serious consequences:
- Inability to pay salaries - employees do not receive their pay on time, which creates liability for the employer and the risk of employee claims.
- Inability to settle liabilities - unpaid invoices to contractors lead to interest, contractual penalties and even termination of contracts.
- Loss of financial liquidity - the company cannot fulfil orders, pay for deliveries or cover its day-to-day operating costs.
- Reputational damage - news of an account freeze can quickly reach business partners and seriously damage the company's reputation.
- Freezing of a spouse's account - if the spouses do not have separation of property, the private accounts of the business owner's partner may also be seized.
Of particular importance, the account freeze takes effect by way of an administrative decision, not a court judgment. The business owner does have the right to appeal, but the procedure takes time - and during that time the company remains without access to its funds. It is precisely this time asymmetry that poses the greatest threat to business continuity.
How to protect your company from an account freeze - preventive measures
In light of the new KAS powers, prevention and professional preparation for a possible inspection become crucial. The risk cannot be eliminated entirely, but it can be significantly reduced by applying proven solutions.
Internal accounting audit
A regularly conducted internal audit makes it possible to detect potential irregularities before the tax authority does. Verifying the accuracy of invoices, the consistency of tax returns with actual bank transactions, and the completeness of documentation is the absolute minimum that every company should do.
Reliable documentation of every transaction
It is worth remembering that the tax authority can challenge not only large financial operations but also seemingly trivial expenses - such as renovations carried out "as a favour" and not documented by invoices. Every transaction should be supported by an appropriate accounting document, and the company's accounts must be complete and transparent.
Separation of property as a safeguard
Business owners who are married should consider establishing separation of property. This is an effective way to protect a spouse's assets from a possible account freeze in the event of a tax inspection. However, this decision requires an analysis of the individual legal and financial situation.
When to contact a lawyer - do not wait for an account freeze
The new rules in force since August 2025 clearly show that a reactive approach to tax matters is now exceptionally risky. Business owners who fail to ensure that their tax settlements and documentation are in order may be caught off guard by an inspection at the least expected moment - and its consequences may be devastating for the company.
Professional legal advice is no longer a luxury but an operational necessity. An experienced lawyer specialising in tax law will help carry out a documentation audit, identify risk areas and prepare a defence strategy in case of an inspection. If an account has already been frozen, response time is crucial, and every day of delay deepens the losses.
Do not wait for the tax authority to freeze your account. Contact our firm today - we will help you protect your company from the consequences of the new KAS rules and effectively represent your interests in the event of a tax inspection. An initial consultation will allow us to assess the risk and plan specific protective measures.
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