Ten major regulatory changes affecting business operations in Poland—some of which companies will feel as early as the start of the year—sum up the fourth quarter of last year in terms of business regulation. This overview comes from the Polish Barometer by TMF Group, prepared by experts from the global firm specializing in compliance and administrative services, which operates 125 offices across 87 tax jurisdictions, including two offices in Poland.
The Polish Barometer by TMF Group is a cyclical report prepared by the TMF Poland expert team—practitioners who support companies operating on the Polish market on a daily basis. The report focuses on administrative, tax, accounting, and employment-related changes that have a tangible impact on business security, costs, and predictability. Among the regulatory changes introduced in the last three months of the previous year are measures that are already in force or will take effect shortly.
Employment seniority reform among positive or neutral changes
Among the changes assessed as positive or neutral for entrepreneurs is the reform of rules for calculating employment seniority, which will take effect on 1 January 2026. The new provisions expand the list of periods counted toward seniority to include, among others, running a business, civil-law contracts (mandate contracts), and work performed abroad. The reform aims to better align regulations with modern labor-market realities and to increase transparency in employee entitlements.
“The new regulations may tangibly improve employees’ situation and increase labor-market transparency. At the same time, for employers they mean the need to verify documentation, recalculate employment seniority, and adapt HR processes to the new rules,”
says Anna Jendo, TMF Group expert.
VAT changes: greater clarity and predictability
Another key area of change in Q4 2025 concerned value-added tax (VAT) regulations. TMF Group experts point to a draft comprehensive amendment to the VAT Act that предусматривает, among other things, harmonizing the moment when the tax obligation arises in selected cases, introducing the institution of a so-called “VAT warehouse,” changes to VAT registration, and clarifying the rules for applying bad-debt relief. Most of the proposed regulations are scheduled to enter into force on 1 July 2026, giving businesses time to prepare.
“The proposed VAT amendments can be seen as a step toward greater transparency and predictability of settlements. Particularly important for entrepreneurs are solutions that may improve liquidity and reduce tax risk in dealings with counterparties,”
notes Mikołaj Ślusarek, TMF Group expert.
KSeF implementing rules and digital invoicing
At the same time, Q4 2025 saw the publication of further implementing regulations for the National e-Invoicing System (KSeF). The new rules, effective 1 February 2026, clarify how to issue structured invoices—including offline and during system outages—as well as the catalogue of exemptions from the obligation to use KSeF. These changes aim to standardize practice and align taxpayers’ obligations with the realities of digital invoicing.
Property tax interpretation and SME facilitations
Among business-friendly measures, the Barometer’s authors also highlight a new general interpretation issued by the Ministry of Finance regarding property tax. The document clarifies that mere ownership of real estate by an entrepreneur does not automatically trigger the highest tax rates; what matters is the actual use of the property in business activity. According to TMF Group experts, this interpretation strengthens taxpayer protection and reduces the risk of disputes with tax authorities.
For the smallest companies, important changes also include the possibility of earlier access to the VAT exemption threshold, as well as new solutions enabling rapid online verification of counterparties via CEIDG and the VAT taxpayers’ register. These measures fit within the government’s deregulation agenda, aiming to simplify procedures and enhance transaction security.
Challenges ahead in 2026
At the same time, the Polish Barometer for Q4 2025 points to a number of changes that may pose serious challenges for businesses in 2026. These include an increase in the health insurance contribution for entrepreneurs due to a return to pre-2025 rules, as well as lower key tax thresholds resulting from changes in the euro exchange rate. Such changes may limit access to preferential tax regimes and increase ongoing financial burdens.
TMF Group experts also note a significant increase in the tax burden for the banking sector following a higher CIT rate effective 1 January 2026. In the authors’ view, this could curb investment and lending in the short term, with indirect effects on other sectors of the economy.
“Many companies will enter 2026 with clearly higher operating costs and greater regulatory uncertainty. Early organizational preparation, impact analysis on operations, and conscious management of tax and employment risks will be crucial,”
emphasizes Magdalena Grzegorczyk, TMF Group expert.
Transparency and digitization—at a cost
The Barometer’s authors point out that some changes—such as the employment seniority reform—are ambivalent in nature. While they pursue important social objectives and bring order to the legal system, for businesses they may mean higher employment costs, additional administrative duties, and potential dispute risks.
“The fourth quarter of 2025 clearly shows that the direction of regulatory change in Poland combines greater transparency and digitization with rising burdens on business. Another challenge is the pace of implementation, as some regulations have already taken effect at the start of the year,”
concludes Magdalena Grzegorczyk, TMF Group expert.
Source: https://ceo.com.pl/co-zmieni-sie-dla-firm-w-2026-r-przeglad-nowych-regulacji-podatkowych-13747
