Polish company VAT registration 2026: VAT-R and the 240,000 zł limit

A sp. z o.o. must file the VAT-R registration form before the day of its first taxable sale (art. 96 ust. 1 of the VAT Act), unless it uses the small-business exemption. From 1 January 2026 the exemption applies as long as net sales in the year do not exceed 240,000 zł, and a proportionally smaller amount in the year the business starts (art. 113 ust. 1 and 9 of the VAT Act).

Law as of 19 October 2026.

Registration is free. A company that sells to businesses from the start, or works in a sector excluded from the exemption, usually registers as an active VAT payer right after its KRS entry. Below: when a company must register, how to count the limit, how to file VAT-R and what changes after registration.

Does a company have to be an active VAT payer?

An exempt company may file VAT-R voluntarily and is then registered as an "exempt VAT payer" (podatnik VAT zwolniony) (art. 96 ust. 3 and ust. 4 pkt 2 of the VAT Act).

The 240,000 zł limit: what counts and what does not

The limit applies to the value of sales excluding VAT, counted per calendar year. The exemption applies only if you went over the limit neither in the previous year nor in the current one (art. 113 ust. 1 of the VAT Act). Until 31 December 2025 the limit was 200,000 zł.

These do not count towards the limit (art. 113 ust. 2 of the VAT Act):

• sales of depreciable fixed assets and intangible assets,
• sales exempt by their nature under art. 43 ust. 1, unless they are real estate transactions, financial services under art. 43 ust. 1 pkt 7, 12 and 38–41 or insurance that are not ancillary transactions for the company,
• intra-EU distance sales of goods that are not taxed in Poland.

For transactions with related parties, the market value counts if the relationship lowers the price (art. 113 ust. 12).

Transitional rule. A business whose sales in 2025 were more than 200,000 zł but not more than 240,000 zł may use the exemption in 2026 (art. 2 of the act of 24 June 2025, Dz.U. 2025 poz. 896).

The limit in the first year: in proportion to the days of business

A company that starts selling during the year counts the limit in proportion to the period of business (art. 113 ust. 9 of the VAT Act). In practice, divide 240,000 zł by the number of days in the year and multiply by the days from the start to 31 December. The year 2026 has 365 days.

The calculation for 1 August: 240,000 zł × 153 / 365 = 100,602.74 zł. When actual sales go over this amount, the exemption ends with the transaction that went over it (art. 113 ust. 10).

When the exemption does not apply

Whatever their turnover, these companies cannot use the exemption (art. 113 ust. 13 of the VAT Act):

• companies providing legal services, advisory services (other than agricultural advice), jewellery services or debt collection, including factoring,
• companies supplying goods from annex 12 (among others precious metals), excise goods (except electricity, tobacco products and company passenger cars), new means of transport, building land, or buildings in the cases of art. 43 ust. 1 pkt 10 lit. a and b,
• companies selling cosmetics, electronics, electrical equipment and machinery online (PKWiU 20.42.1, 26, 27, 28),
• companies selling parts and accessories for cars and motorcycles, wholesale or retail.

The "advisory" exclusion covers many services that companies describe as consulting. If your service consists of advising a client, assume you file VAT-R before the first invoice.

Going over the limit: an example

An exempt company sells services to businesses. By 20 November 2026 its net sales are 232,000 zł. On 25 November it performs a service for 12,000 zł net, so total sales rise to 244,000 zł.

The exemption ends with the service that took the company over the limit, so VAT is due on the whole 12,000 zł, not only on the 4,000 zł excess (art. 113 ust. 5 of the VAT Act). The company must file VAT-R before the day of that service (art. 96 ust. 5 pkt 2). It can return to the exemption at the earliest one year after the end of the year in which it lost it, so after a loss in 2026, from 1 January 2028 (art. 113 ust. 11).

How to register a company for VAT, step by step

1. Fill in VAT-R in its current version (18). Tick the purpose: registration as an active or an exempt VAT payer, and the date from which you want to be registered.
2. Tick VAT-UE if you need it. In the same form you report intra-EU transactions and purchases of services from EU businesses (art. 97 ust. 1 and 3 of the VAT Act). Details in the next section.
3. File it with the tax office for the company's registered seat. You can do this online in e-Urząd Skarbowy on the organisation account, electronically with the qualified signature of a person representing the company, in person or by post. A special power of attorney (PPS-1) costs 17 zł in stamp duty.
4. Do not pay for registration. Filing VAT-R is free. The 170 zł fee applies only to a confirmation of registration, which you may request (art. 96 ust. 4 of the VAT Act, part I item 16 of the annex to the Stamp Duty Act).
5. Answer the tax office's questions. The office verifies the data and may ask for documents, for example your legal title to the premises. It will not register the company if the data are false, it cannot contact the company, or the company does not respond to summonses (art. 96 ust. 4a).
6. Check the white list. After registration the company appears in the register of VAT payers kept by the Head of KAS, known as the white list (art. 96b of the VAT Act). Business partners check your status and bank account there.

An exempt company and VAT-UE: ads and services from abroad

Many young companies buy ads, software or hosting from businesses in other EU countries. This is an import of services: the buyer settles the VAT, including an exempt company (art. 17 ust. 1 pkt 4 of the VAT Act). Before the first such purchase the company must register as an EU VAT payer (art. 97 ust. 3 pkt 1).

An exempt company that does not file JPK_V7 reports VAT on imported services in the VAT-9M return by the 25th of the month after the month of purchase (art. 99 ust. 9 of the VAT Act). It cannot deduct this VAT, so VAT on services from abroad is a cost for it.

Active or exempt: which pays off

The exemption helps when your customers are consumers: the price without VAT is lower for them. When you sell to businesses, active status usually pays off, because the customer deducts the VAT anyway and you deduct VAT on your purchases. Only an active VAT payer may deduct (art. 88 ust. 4 of the VAT Act).

Example: a company sells services to businesses for 15,000 zł net a month and buys software, equipment and services for 4,000 zł net plus 920 zł VAT. As an active VAT payer it deducts 920 zł a month, 11,040 zł a year. As an exempt company it carries this VAT as a cost.

You can switch either way:

• Giving up the exemption: a written notice before the start of the month from which you give it up (art. 113 ust. 4 of the VAT Act), and VAT-R before that month (art. 96 ust. 5 pkt 3).
• Returning to the exemption: at the earliest one year after the end of the year in which you gave it up (art. 113 ust. 11).
• Adjusting input VAT: after the change of status you adjust VAT on unused goods and on fixed assets worth more than 15,000 zł within the adjustment period (art. 91 ust. 7, 7a and 7d of the VAT Act).

Duties of an active VAT payer

• JPK_V7M by the 25th of the following month (art. 99 ust. 1 of the VAT Act). For the first 12 months after registration you cannot file quarterly (art. 99 ust. 3a pkt 1).
• Invoices in KSeF. An active VAT payer issues invoices to businesses in the National e-Invoicing System (KSeF). An exempt company need not issue invoices unless the buyer asks for one (art. 106b ust. 2 and 3). How a company issues invoices in KSeF is covered in our article on KSeF for a sp. z o.o..
• Changes to the VAT-R data must be reported within 7 days (art. 96 ust. 12).
• Risk of removal. The office removes a payer that has not filed JPK for 3 months in a row, or has shown no sales and no purchases for 6 months (art. 96 ust. 9a pkt 2 and 3). You can apply for reinstatement within 2 months (art. 96 ust. 9h).

VAT-R is one of the first steps after the KRS entry. The others are in our guide how to start a sp. z o.o..

How Norman helps

Norman runs the accounting of a sp. z o.o. or a sole trader (JDG) in Poland: you issue invoices in PLN, pull purchase invoices from KSeF and match bank payments to documents. Norman prepares the JPK_V7 file every month, and you check it and send it. You can issue your first invoice after registration for free and without an account in the KSeF invoice generator, and read more about Norman on the home page.

Frequently asked questions

How much does VAT registration cost for a company?

Nothing. Filing VAT-R is free. You pay the 170 zł stamp duty only if you want a confirmation of registration.

What is the VAT exemption limit in Poland in 2026?

240,000 zł of net sales a year (art. 113 ust. 1 of the VAT Act). In the year the business starts, the limit is proportional to the days of business, for example 100,602.74 zł for a start on 1 August 2026.

When must a company file VAT-R?

Before the day of its first taxable sale, and if it uses the exemption, before the day it goes over the limit (art. 96 ust. 1 and ust. 5 pkt 2 of the VAT Act). A company providing advisory or legal services registers before its first invoice.

Does a VAT-exempt company need VAT-UE?

Yes, if it buys services from businesses in other EU countries, for example online ads. It registers as an EU VAT payer before the first purchase and reports VAT on imported services in VAT-9M (art. 97 ust. 3 pkt 1, art. 99 ust. 9 of the VAT Act).

After going over the limit, can I return to the exemption from the new year?

Not straight away. You can return at the earliest one year after the end of the year in which you lost the exemption. After going over in 2026, that is 1 January 2028 (art. 113 ust. 11 of the VAT Act).