A digital revolution in invoicing, a landmark EU judgment on VAT and a proposed new European company form, alongside more expensive company cars, new powers for labour inspectors and the end of wartime simplifications in hiring foreign workers — these are among the changes expected to shape business operations in Poland in 2026, according to the Polish Barometer by TMF Group for the first quarter of 2026.
The Polish Barometer by TMF Group is a cyclical report prepared by experts at TMF Poland, who work on a daily basis from the company’s offices in Katowice and Warsaw. The report focuses on administrative, tax, accounting and employment-related changes that have a tangible impact on the security, costs and predictability of doing business. The first quarter of 2026 brought both changes favourable to companies and developments requiring rapid adjustment of internal processes.
Among the changes assessed as positive or neutral for entrepreneurs, the authors of the Barometer point first to the judgment of the General Court of the European Union of 11 February 2026. The ruling challenges one of the more burdensome mechanisms in Poland’s VAT system: the compulsory deferral of the right to deduct input VAT solely because an invoice arrived late. The Court ruled that a taxpayer may deduct input VAT in the return for the period in which the transaction took place, even if the invoice was received in the following month, provided that the document is in the taxpayer’s possession before the tax return is submitted. The matter has not yet been finally resolved, however, as a request for special review of the judgment has been filed, leaving the Court of Justice of the European Union to issue the definitive decision.
“This ruling should be treated as one of the most important tax decisions of recent years — not only from a technical and legal perspective, but above all from an economic one. Artificially delaying the right to deduct VAT by an entire settlement month generates real costs for companies. Time will tell how this case ends and what final impact it will have on Polish taxpayers,” comments Mikołaj Ślusarek, expert at TMF Group.
Another important development highlighted by the authors of the Barometer is the European Commission’s proposal, presented on 18 March 2026, for an EU Inc. regulation introducing a new company form.
An EU Inc. European company would be automatically recognised in all EU member states, while registration would be fully digital, take no more than 48 hours and cost no more than EUR 100. It would operate alongside the 27 national legal systems as a so-called “28th regime”.
The proposal is also accompanied by plans to create a digital European Business Wallet, enabling companies to file tax returns and apply online for business-related permits. It also envisages an EU employee stock option model, under which taxation would occur only when shares are sold, as well as simplified insolvency procedures for startups.
“The EU Inc. initiative is a direct response to one of the most pressing problems of European competitiveness. For years, European startups have been moving to Delaware, London or Singapore in search of a simpler legal environment. The legal form of the instrument is crucial: a regulation, not a directive. In this way, the Commission wants to eliminate the risk of fragmentation, which has often undermined the effects of EU reforms,” says Mikołaj Ślusarek, expert at TMF Group.
A breakthrough moment for Polish entrepreneurs also came on 1 April 2026, when the second and largest stage of the National e-Invoicing System, KSeF, was implemented. From that date, almost every entrepreneur issuing invoices in Poland became obliged to use the system. The final group, micro-entrepreneurs with monthly sales of up to PLN 10,000, will join KSeF from 1 January 2027. At the same time, the Ministry of Finance is working on a new mechanism for identifying so-called scam invoices, meaning false cost invoices, which can be reported via a form in the KSeF 2.0 application from 1 February 2026.
“This is a historic moment for the digitalisation of Poland’s tax system, but also a real operational test on an unprecedented scale: hundreds of thousands of entities in one system at the same time. Entrepreneurs are now entering the most difficult stage — not the technical one, but the process-related one. KSeF changes not only the tool used to issue invoices, but the entire document circulation cycle within a company. The year 2026 is a transitional period with a formal absence of sanctions, but the habits and procedures developed now will determine companies’ tax security from 2027,” stresses Mikołaj Ślusarek, expert at TMF Group.
TMF Group experts also see the amendment to the Accounting Act, signed by President Karol Nawrocki on 11 March 2026, as a clearly positive change. It allows thousands of Polish companies to legally withdraw from costly ESG reporting for 2025 and 2026. The exemption applies to entities that did not exceed the threshold of 1,000 employees or PLN 1.9 billion in net sales revenue in the financial year and the preceding year. The amendment implements an option provided for in EU Directive 2026/470, known as the Omnibus I package, which from 2027 will narrow the ESG reporting obligation to companies that simultaneously exceed the thresholds of 1,000 employees and EUR 450 million in revenue.
“This is one of those changes that companies will feel in practice — not only in their budgets, but also in the work schedules of finance and ESG departments. The cost of preparing a full sustainability report compliant with European ESRS standards may range from several hundred thousand to even several million złoty annually, including audits, data collection systems and human resources,” comments Magdalena Grzegorczyk, expert at TMF Group.
Entrepreneurs should also note a new functionality in the mObywatel application, which, under the Act of 9 January 2026, will be integrated with the National Court Register. The full functionality is scheduled to be launched on 31 May 2026. Shareholders, management board members and commercial proxies will receive automatic push notifications about registry changes for up to 50 entities in each communication channel. In parallel, from 31 March, electronic documents generated from land and mortgage registers gained the full legal force of court documents.
“For entrepreneurs linked to multiple entities, the new tool represents a real saving of time and an improvement in corporate control standards at no additional cost. However, it is worth remembering the limit of 50 entities per channel,” says Magdalena Grzegorczyk, expert at TMF Group.
The authors of the Barometer also positively assess the modernisation of the rules on using sick leave. The reform has been implemented in stages since January, with key provisions entering into force on 13 April 2026. The most important change is a new approach to activity during sick leave: the key criterion is now solely the impact of a given activity on the recovery process. Incidental contact with the workplace — such as answering a phone call or replying to an email — no longer automatically results in the loss of sickness benefit.
“The reform of the sick leave system is one of those changes that had been needed for years. The new criterion — the impact of an activity on treatment — is much more rational and proportionate. For companies, this is a signal that the system is beginning to keep pace with the market. At the same time, strengthening ZUS inspections is the right direction: effective enforcement of the rules protects those who use sick leave honestly and eliminates abuses that burden the entire system,” says Anna Jendo, expert at TMF Group.
The seventh and final change classified by TMF Group experts as positive concerns the reform of rules on employing foreigners, adopted on 5 March 2026. The reform is intended to bring order to years of legal confusion in this area. On the one hand, the new provisions maintain temporary protection for Ukrainians holding a PESEL UKR number. On the other, they require employers to notify the district labour office of the employment of a foreign national within seven days and give companies a three-year transition period to fully adjust to the new requirements.
“It is particularly important that temporary protection for Ukrainians with a PESEL UKR number has been preserved — proof that the legislator is not acting mechanically and is not withdrawing acquired rights. Standardising procedures for other groups is a step towards a more equal and predictable labour market,” says Anna Jendo, expert at TMF Group.
However, the first quarter of 2026 also brought changes posing serious challenges for Polish entrepreneurs. Among them, the authors of the Barometer point above all to the reduction, from 1 January 2026, of the tax-deductible cost limit for combustion-engine cars and most hybrids — from PLN 150,000 to PLN 100,000. The new system of limits depends on CO2 emissions: PLN 225,000 for electric and hydrogen-powered vehicles, PLN 150,000 for vehicles emitting less than 50 g/km, and PLN 100,000 for all combustion-engine cars and most hybrids. The limits apply not only to depreciation write-offs, but also to leasing instalments and rental fees, meaning the forms of financing most commonly chosen by entrepreneurs.
“This is a change that hits where it hurts most — the day-to-day cost calculation of running a business. The PLN 100,000 limit is clearly detached from market prices: since 2019, new car prices have risen by 50–100%, and today an average mid-range car costs PLN 150,000–200,000. This means that half or more of its value is excluded from tax-deductible costs,” explains Magdalena Grzegorczyk, expert at TMF Group.
Another major challenge is the reform of the National Labour Inspectorate, which grants a district labour inspector the right to independently issue an administrative decision confirming the existence of an employment relationship — without a court judgment — resulting in the immediate reclassification of a contract. Although the reform is aimed at fictitious B2B contracts, thousands of professionals, including programmers, graphic designers and consultants, consciously and voluntarily operate in this form, valuing its flexibility. For them, TMF Group experts point out, the new regulations create a risk of incorrect assessments by inspectors, which could affect companies operating legally.
“The reform of the National Labour Inspectorate may produce good results in combating labour market abuses, but if implemented poorly — without precise criteria and proper control over inspectors’ discretion — it may become a tool that also harms legally operating companies and conscious freelancers,” warns Anna Jendo, expert at TMF Group.
Finally, the authors of the Barometer draw attention to the negative consequences of the previously mentioned reform of rules on employing foreigners. For the construction, logistics and manufacturing sectors, the changes may pose a real threat to operational continuity. The new procedures extend the recruitment process for foreign workers, while the seven-day notification deadline represents an additional operational cost and a risk of sanctions for thousands of small and medium-sized companies. Another risk concerns employees without a confirmed PESEL UKR number: if they fall out of the legal labour market, this would create a real staffing gap that no one is currently able to plan for.
“The changes will be felt most strongly by employers hiring Ukrainians without a PESEL UKR number. It is precisely for these workers that the path to legal employment is becoming more formalised and closer to the standards applicable to citizens of other countries,” says Anna Jendo, expert at TMF Group.
