Unregistered business activity 2026 - limit, rules and settlement

What unregistered business activity is

Unregistered business activity (also called non-recorded activity or a 'trial firm') is small-scale earning activity carried out by a natural person whose income does not exceed the statutory limit. Even though you earn, formally this is not business activity within the meaning of the Entrepreneurs' Law, so it does not carry the obligations typical of a firm.

It is a convenient solution to start with: it lets you test an idea, earn extra alongside a job or sell your own handmade goods without setting up a firm. It is available to a person who has not run a business in the last 60 months.

• No entry in CEIDG and no REGON number (statistical ID).
• No ZUS contributions - neither social nor health.
• No obligation to pay monthly tax advances.
• Tax settled once a year, in the annual return.

Income limit 2026 - the change from monthly to quarterly

This is the most important change of 2026. Until the end of 2025 the limit was counted monthly - income in a given month could not exceed 75% of the minimum wage. From 1 January 2026 a quarterly limit applies: income due from the activity may not exceed 225% of the minimum wage in any quarter.

The change stems from Article 5 of the Act of 25 July 2025 amending certain acts in order to simplify administrative procedures and support entrepreneurship (Journal of Laws 2025, item 1168), which entered into force on 1 January 2026. Counting the limit on a quarterly basis gives more flexibility with seasonal and irregular income - you can have one very good month, as long as the whole quarter stays within the limit.

• Minimum wage in 2026: PLN 4,806 gross (applies for the whole year, with no rise in July).
• Quarterly income limit: 225% of PLN 4,806, i.e. PLN 10,813.50.
• The limit applies to income due - amounts owed count, even if the client has not yet paid.
• The limit relates to each quarter separately, not to the whole year.

We give the amounts cautiously, as they stand for 2026. If the minimum wage changes during the year, the amount of the limit will change too - so before a borderline sale it is worth checking the current figure.

Without CEIDG, ZUS and NIP - what you do not have to do

When running unregistered business activity, you are exempt from most of the formalities that burden a sole proprietorship. You do not register the activity in CEIDG and you do not obtain a REGON number.

You also do not pay ZUS contributions - neither social nor health - because from an insurance perspective you are not an entrepreneur. As a rule you also do not need a NIP or VAT registration; you use your PESEL number (national identification number).

You do, however, have to keep the exceptions in mind. The obligation to register for VAT and to have a cash register may arise for certain activities regardless of scale - we write about this further on in the guide.

Sales records and documentation

Although there are few formalities, one obligation remains: you must keep a simplified sales record. This is a simple list of income in which you note successive transactions on a cumulative basis. The record lets you monitor whether you are approaching the quarterly limit, and it is the basis for the annual settlement.

What the record should contain

• A sequential number and the date of sale.
• The income amount from a given transaction.
• The cumulative income value from the beginning of the year.
• You can keep the record in a notebook, a spreadsheet or a simple program.

At the buyer's request you are obliged to issue a bill or invoice. A VAT-free invoice (a so-called simplified invoice for a person exempt from VAT) contains, among other things, the date, the parties' details, a description of the sale and the amount - it need not contain a NIP if you do not have one.

When VAT and a cash register come into play

Unregistered business activity as a rule benefits from a VAT exemption, because income is low - in 2026 the threshold for the subjective VAT exemption is PLN 240,000 of turnover per year. There are, however, activities for which VAT is compulsory from the first sale, regardless of the amount.

• Compulsory VAT applies, among others, to the sale of certain goods (e.g. articles made of precious metals) and selected services, such as legal or advisory services.
• In such a case you register as a VAT taxpayer (the VAT-R form) and obtain a NIP before the first sale.
• The cash register exemption applies as long as sales to private individuals do not exceed PLN 20,000 per year (pro rata if you start during the year).
• Some industries require a cash register from the first sale - for example hairdressing, cosmetic or catering services.

This is an area where it is easy to make a mistake. If you are not sure whether your sales are covered by the VAT or cash register obligation, we will check the rules for your type of activity and present which obligations apply to you - you make the decision yourself.

Settlement in PIT - the annual return

Income from unregistered business activity is treated as income from other sources. You do not pay tax advances during the year - you settle only in the annual return, filed on the PIT-36 form.

PIT-36 has a separate line for unregistered business activity, in which you report the income, costs, profit and tax due. The profit from this activity is combined with other income taxed under the scale (e.g. from an employment contract) and is covered by the tax-free amount.

• The basis is the profit, i.e. income reduced by documented costs of earning it.
• Taxation under the scale: 12% up to PLN 120,000 of the base and 32% on the excess.
• You file the PIT-36 return between 15 February and 30 April for the previous year.
• Costs (e.g. materials, purchase of goods) are worth documenting with invoices from the start of the activity.

When you have to register a business

Unregistered business activity has its limits. At the moment income due exceeds the quarterly limit, the activity becomes business activity by operation of law. From the day the limit is exceeded you have 7 days to file an application for entry in CEIDG.

Some types of activity cannot be carried out in unregistered form at all - this concerns activities requiring a concession, a permit or an entry in the register of regulated activity. In such cases a registered firm is needed from the outset.

• Exceeding the quarterly income limit - registering a sole proprietorship within 7 days.
• Activity requiring a concession or permit (e.g. the sale of alcohol, security services).
• Activity entered in the register of regulated activity.
• Activity within a civil-law partnership - it cannot be unregistered.

Switching to business activity need not mean high costs at the start - a new entrepreneur usually benefits from the start-up relief and preferential ZUS. We will help you through the registration when the time comes.

How Luno-Group helps with unregistered business activity

At Luno-Group we provide online accounting, but behind the settlements stand experienced accountants, not the app alone. This means you can talk to a real person about your situation - including when you are only testing a business idea.

We will help set up the sales record, check whether your sales are covered by the VAT or cash register obligation, and settle the income correctly in PIT-36. When you approach the limit or decide on a full firm, we will guide you through registration in CEIDG and ongoing accounting.