The VAT amendment - what is changing and why does it matter?
On 2 June 2026, the Council of Ministers adopted a draft act amending the act on goods and services tax (VAT) and the rules on the records and identification of taxpayers. It is the most extensive package of VAT changes in several years and will directly affect the day-to-day accounting duties, cash flow and time spent on formalities of thousands of Polish businesses.
The main aims of the amendment are to reduce administrative obligations, clarify provisions that have raised questions of interpretation, tighten the tax system and bring Polish law into line with the latest case law of the Court of Justice of the European Union (CJEU). The changes will be introduced in stages - from October 2026 until July 2028 - giving companies time to prepare their systems and internal processes.
VAT is one of the most important sources of state budget revenue, yet it is also one of the most complex fiscal burdens. Every change to the rules requires careful legal analysis, so it is worth getting to know the upcoming changes in advance and assessing their impact on your business.
Less red tape - an end to unnecessary obligations
One of the pillars of the new regulation is the abolition of selected reporting obligations which created extra work without real value for tax audits. The most important simplifications include:
- Abolition of the obligation to submit a separate stocktake notification - the physical count of goods remains mandatory, but the additional formal reporting of this fact to the tax office disappears.
- Dropping the requirement to show the tax base in the JPK_VAT for purchases from foreign taxpayers relating to goods and services exempt from VAT - removing this requirement will reduce recording errors in the monthly Standard Audit File (JPK).
- Abolition of the obligation to pay VAT within 14 days of the intra-Community acquisition of a means of transport - the settlement will follow the general rules, which will significantly improve the cash flow of transport companies and businesses expanding their fleets.
- Limiting the charging of interest on import VAT where the delay is not the taxpayer's fault - an important element of protecting importers from penalties for errors on the part of financial institutions or customs authorities.
Each of these solutions may seem a small step on its own, but together they form a significant package that relieves the burden on accounting departments and accounting firms. For small and medium-sized businesses, this means real savings in time and money.
VAT warehouses and TAX FREE digitalisation - new tools for business
The VAT warehouse regime
A genuine novelty in the Polish legal system will be the VAT warehouse - a regime already well known in many Western European countries. Its essence is the suspension of VAT collection until the goods are taken out of the designated warehouse onto the domestic market. For large-scale importers and distributors, this means a dramatic improvement in cash flow and greater competitiveness on international markets. The VAT warehouse rules will come into force on 1 January 2027.
Historical verification of counterparties
The amendment also introduces the possibility of checking a taxpayer's VAT status up to five years back. This is a key tool for exercising due diligence when selecting counterparties. Businesses will gain an effective way to minimise the risk of losing the right to deduct input VAT and to protect themselves against unknowing involvement in VAT carousel fraud.
Electronic TAX FREE clearance
The retail and tourism sectors will benefit from the digitalisation of the VAT refund procedure for travellers. The draft provides for the introduction of e-TAX FREE clearance carried out via terminals at points of sale. This solution will speed up the service of foreign customers and reduce paper documentation. Full implementation of electronic clearance is planned for 1 July 2028.
Clarified rules and a tighter system
A significant part of the amendment focuses on tidying up areas of tax law that have generated interpretation disputes for years. Among other things, it clarifies the moment the tax obligation arises for supplies of goods or services made against compensation under decisions of public authorities, for example in the case of expropriations. It also regulates the rules for accounting for supplies of electricity and the use of the VAT exemption for small businesses.
An important novelty is the regulation of the rules for accounting for deposits under the packaging deposit return system - a key issue given the rollout of a universal deposit return system in Poland. The use of the reduced VAT rate on disinfectant products has also been permanently regulated, which is a legacy of the pandemic experience.
To tighten the system, the government plans to extend the joint and several liability of buyers for the tax arrears of unreliable sellers and to tighten taxpayer registration rules to make it harder to set up shell companies. The phasing out of old-type cash registers in favour of online cash registers will also speed up - from 1 July 2027, an absolute ban on replacing the fiscal memory in old devices will apply. In the split payment mechanism, the classification of goods will change - from the Polish Classification of Products and Services (PKWiU) to the international Combined Nomenclature (CN).
Timetable for entry into force and alignment with EU law
The changes will be introduced in four stages, allowing businesses and accounting firms to adapt their IT systems gradually:
- 1 October 2026 - most of the administrative simplifications and legal clarifications.
- 1 January 2027 - launch of the VAT warehouse, abolition of accelerated VAT payment on intra-Community acquisitions of vehicles, new obligations regarding the deregistration of cash registers.
- 1 July 2027 - absolute ban on replacing the fiscal memory in old-type cash registers.
- 1 July 2028 - full implementation of electronic TAX FREE clearance.
The amendment also implements solutions arising from CJEU case law. People running a joint farm will gain the right to be treated as separate VAT taxpayers. The possibility of applying the zero VAT rate to services related to the import of goods will be extended, and the rules on the right to deduct VAT will be updated in line with the Court's current, pro-business line of case law.
How to prepare your company for the new rules
The scale of the changes is significant and affects virtually every aspect of VAT accounting - from records and payments to cash registers and international trade. Businesses that carry out an audit of their tax processes early enough will be able not only to avoid costly mistakes but also to make full use of the new simplifications and tools.
Our firm is continuously monitoring the progress of the legislative work and is ready to support your company in preparing for the upcoming changes. We offer a comprehensive analysis of the impact of the amendment on your business, help with implementing new procedures and ongoing tax advice. Contact us today to arrange a consultation and be confident that your company will be fully prepared for the new VAT rules.
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