Poland's Act poz. 1270 changes the small-business VAT exemption limit and joint liability rules from 2027, and TAX FREE confirmation from 2028

What changed in detail

The Act of 4 September 2026 (Dz.U. 2026 poz. 1270), which also introduces the VAT warehouse regime, makes four other changes.

First, supplies under art. 13(3) now count towards the sales value used for the subjective VAT exemption for small businesses (new art. 113(1a)).

Second, it rewrites the joint-and-several liability rule in art. 105a around a revised annex 15 and a new annex 16. There is a carve-out for service purchases where the invoice total is below PLN 15,000 gross, unless net purchases from one supplier exceed PLN 50,000 in a month.

Third, from 1 July 2028, travellers may obtain TAX FREE export confirmation through a terminal at designated border crossings (new art. 128(3a), with the terminal definition in art. 2 pkt 46a and the border-crossing list in art. 130(5)).

Fourth, a PLN 300 penalty is introduced for failing to apply to deregister a cash register by the deadline.

The provisions are effective from 1 January 2027, except those listed in art. 9: the TAX FREE terminal provisions apply from 1 July 2028, and art. 1 pkt 27 (cash register rules) from 1 January 2028.

What it means

The exemption-limit change matters most to businesses near the exemption limit, since art. 13(3) supplies now count towards it. The joint-liability carve-out has two thresholds that work together, PLN 15,000 gross per service invoice and PLN 50,000 net per supplier per month, so buyers need to track both. The TAX FREE terminals come later than the rest, so retailers in the scheme have until 1 July 2028. The cash-register penalty is small but applies if the deadline is missed.