Guide · VAT
Updated: · 7 min read · By Agnieszka Saladra, Certified Accountant
Not every business has to account for VAT (value added tax) right away. We explain when the tax becomes mandatory, what exemption threshold applies in 2026, and who cannot benefit from it. We also show how our accounting firm keeps an eye on these thresholds for you.
In short
VAT is the tax on goods and services, added to the price of almost every sale. An active VAT taxpayer charges it on invoices, pays the tax office the difference between output and input tax, and files JPK_V7 records (the standardised VAT ledger file) every month. This is a real obligation, which is why many small businesses use the exemption when starting out.
The most common is the subject-based exemption (zwolnienie podmiotowe) - available because of low sales value. As long as you do not exceed the statutory threshold, you do not have to register for VAT, you do not charge it on invoices, and you do not file returns. This is a significant simplification of bookkeeping, especially for a sole proprietorship (JDG).
The exemption, however, is not for everyone. Both the level of turnover and the type of activity carried out matter - which we discuss in the following sections.
From 1 January 2026, the subject-based VAT exemption threshold increased from PLN 200,000 to PLN 240,000 of annual sales value. This is the first increase of this threshold in many years - thanks to it, more micro-businesses can stay outside the VAT system.
Importantly, the change covered not only new businesses. A transitional provision allowed a return to the exemption as early as 1 January 2026 also for those whose sales in 2025 exceeded PLN 200,000 but did not exceed PLN 240,000 - with no one-year waiting period. That window has now closed. Today the general rule of Article 113(11) of the VAT Act applies: anyone who lost the right to the exemption or gave it up may return to it at the earliest after one year has passed, counting from the end of the year in which this happened.
Keeping track of this threshold during the year can be difficult when there are many invoices. In practice, this is one of the moments when a costly mistake is easiest to make, which is why online accounting with ongoing turnover monitoring is very helpful here.
VAT 2026 - exemption versus obligation. Legal status as of 2026; for information purposes only and does not constitute tax advice.
| Situation | Rule |
|---|---|
| Subject-based exemption threshold | PLN 240,000 of annual net sales value from 1 January 2026 (previously PLN 200,000). |
| Starting a business mid-year | The threshold is counted proportionally to the number of days the business operates in a given year - if you start mid-year, the threshold is correspondingly lower. |
| Activities with no right to exemption | VAT from the first sale, regardless of turnover - including legal, advisory, and jewellery products (Article 113(13) of the VAT Act). |
| Registration | Filing the VAT-R form with the tax office before the first activity subject to VAT - that is, before you issue the invoice that exceeds the threshold. |
| Object-based exemption | Independent of the level of turnover (Article 43 of the VAT Act) - e.g. medical, educational, financial, and insurance services. |
Some entrepreneurs are VAT taxpayers from the very first zloty - regardless of turnover. The list of exclusions is set out in Article 113(13) of the VAT Act and covers specific goods and services.
If you run a business from this list, you must register for VAT before your first transaction. Even very low turnover will not help here. The line can be thin - for example, not every advisory activity is automatically a VAT-excluded 'advisory service', so it is worth consulting the classification with an experienced accountant before you make a mistake.
Alongside the subject-based exemption there is the object-based exemption (zwolnienie przedmiotowe), described in Article 43 of the VAT Act. It applies to specific types of services and is available regardless of the level of sales - you may have multi-million turnover and still be VAT-exempt on a given service.
The object-based exemption has its pitfalls, however - for example, medical services performed for purposes other than health may already be subject to VAT. Each case is worth assessing individually, because an incorrect classification means overdue tax along with interest.
You register for VAT using the VAT-R form. You file it with the tax office when you exceed the exemption threshold, start an activity excluded from the exemption, or voluntarily wish to become an active taxpayer - you then deduct VAT on purchases, but also charge it on your own invoices.
The application must be filed before the first activity subject to VAT, that is, before you issue an invoice exceeding the threshold. A delay means a tax arrears.
If you buy or sell goods or services to companies from other European Union countries, you need an additional EU VAT (VAT-UE) registration (also via the VAT-R form). After it, you use your tax ID number (NIP) with the PL prefix and file monthly EU VAT recapitulative statements. This obligation also applies to some businesses exempt from domestic VAT - for example, when buying services from abroad. This is a frequent topic in accounting for e-commerce and cross-border businesses.
Being an active VAT taxpayer comes with two tools that must not be ignored.
This is a public register of active VAT taxpayers, maintained by the Ministry of Finance, with a list of bank accounts. For payments above PLN 15,000 you should transfer funds only to an account from the white list. Otherwise you cannot include the payment as a tax-deductible cost, and the tax authority may demand from you the VAT that your contractor failed to pay.
In the split payment model, the net amount goes to the seller's business account and the VAT to a dedicated VAT account. For invoices above PLN 15,000 covering goods and services from Annex 15 to the Act (including electronics, steel, fuels, and construction services), split payment is mandatory, and the invoice must include the note 'split payment mechanism' ('mechanizm podzielonej platnosci'). Paying via split payment also protects against penalties related to the white list.
VAT is an area where mistakes are easiest to make - from missing the threshold, through incorrect classification of a service, to failing to apply split payment. Each of these errors can cost real money.
At Luno-Group, an experienced accountant looks after your settlements, not an app alone. We combine the convenience of online accounting with real human support from someone who knows the regulations and will answer your questions.
Sources and legal basis
From 1 January 2026, the subject-based VAT exemption threshold is PLN 240,000 of annual net sales value - previously it was PLN 200,000. Once you exceed this amount, you must register as an active VAT taxpayer.
Among those who cannot use the subject-based exemption are companies providing legal, advisory, and jewellery services, as well as those selling new means of transport or certain excise goods. These industries are VAT taxpayers from the first transaction, regardless of turnover.
Yes. If you start your activity during the year, you calculate the PLN 240,000 threshold proportionally to the number of days the business operates. If you start mid-year, you are therefore entitled to a correspondingly lower exemption threshold.
You make the EU VAT (VAT-UE) registration before the first intra-Community transaction - the sale or purchase of goods or services from EU companies, as well as the import of services. The VAT-R form is used for this, and after registration you file monthly recapitulative statements.
The white list is a register of active VAT taxpayers and their accounts, which you check before a payment above PLN 15,000. Split payment is a payment method that splits the amount into net and VAT - mandatory for invoices above PLN 15,000 covering goods from Annex 15.
No. An entrepreneur exempt from VAT does not charge it on invoices, but also does not deduct the tax on purchases. Voluntary registration as an active taxpayer lets you deduct VAT on purchases, but also means charging it on your invoices - a decision worth discussing with an accountant.