Newsletter IC&PARTNERS POLAND – 2026-10
Major fiscal, administrative, and labour updates
1. New rules for the conferral of the general power of attorney in tax matters
2. Changes to the methods of transmission of information on tax mechanisms (MDR)
3. New provisions on the use of artificial intelligence in companies
4. Extension of the SENT system to certain goods classified under heading CN 1518
5. Increase in the minimum wage from 1 January 2027
6. Changes to VAT legislation from 1 January 2027
7. Simplifications envisaged for the deductibility of transaction costs above PLN 15,000
8. Tax treatment of the refund of sickness contributions to entrepreneurs
9. Medical certificates relating to preventive examinations of workers in electronic format
New models of general power of attorney in tax matters (PPO-1 and OPO-1)
From 1 October 2026, the new models of the General Power of Attorney in Tax Matters (PPO-1) and the Communication on the Amendment, Revocation or Waiver of the Power of Attorney (OPO-1) are in force. The changes stem from the revision of the Polish Tax Ordinance, which has expanded the possibility of being represented by a Prosecutor General also for persons who are not formally parties to proceedings, but who are invited by the tax authority to provide clarifications or submit documents.
What are the main implications for taxpayers?
The general power of attorney allows the representative to act on behalf of the taxpayer in tax matters, without having to grant a separate power of attorney for each individual proceeding. The new provisions expand the situations in which this form of representation can be used.
It is important to remember that:
• from 1 October 2026, the new PPO-1 and OPO-1 forms must be used for the conferral of the general power of attorney and for the communication of the related amendments;
• general powers of attorney granted before this date remain valid and do not need to be renewed solely because of the updating of the forms.
Companies that use representatives in dealing with tax authorities should check that the representation arrangements adopted are appropriate for their current needs.
New ways of transmitting information on cross-border or tax arrangements (MDRs)
From 1 October 2026, information on tax arrangements subject to mandatory reporting (MDR) must be submitted electronically, through the software made available by the Polish tax administration. Communications must be signed with a qualified electronic signature or with a Polish fiduciary electronic signature (podpis zaufany). Proof of correct transmission is the official electronic receipt generated by the system of the Head of the National Revenue Administration (Szef KAS).
Entities subject to MDR obligations should audit their internal procedures and ensure that they comply with the new technical and formal requirements.
New provisions on the use of artificial intelligence in companies
According to the regulatory reference material, new national provisions on artificial intelligence systems are expected to enter into force from 28 October 2026. The obligations indicated include, among other things, the mapping of the algorithmic tools used in the company, the development of employees' skills and the human supervision of artificial intelligence systems.
Companies should evaluate how AI tools can be used by staff and consider introducing a specific company policy. This document should identify the authorized tools, the categories of data that can be entered into the systems and the information that cannot be transferred outside the company infrastructure.
Extension of the SENT system to certain goods classified as CN 1518
From 31 October 2026, the Polish transport monitoring system SENT will also be extended to certain goods classified under customs heading CN 1518, including used cooking oils. The obligation will concern shipments with a gross weight of more than 500 kg or a volume of more than 500 liters, subject to the exclusions provided for by the legislation.
Undertakings involved in the collection, transport or processing of such products should check the classification of the goods and ascertain whether the transports carried out require reporting in the SENT system. Failure to report or provide incorrect data may result in significant financial penalties.
Increase in the minimum wage from 1 January 2027
From January 1, 2027, the minimum monthly wage in Poland will be PLN 4,950 gross, while the minimum hourly rate will be PLN 32.30 gross. Compared to 2026, the increase will be PLN 144 per month for the minimum wage and PLN 0.90 for the minimum hourly rate.
Employers should take the new thresholds into account when planning personnel costs for 2027. The increase may affect not only the salaries of the employees concerned, but also other benefits and allowances calculated on the basis of the minimum wage.
Changes to VAT regulations from 1 January 2027
From 1 January 2027, amendments to the Polish VAT Act are planned, including the simplification of certain declaration obligations, the introduction of the VAT warehousing regime and the extension of the buyer's joint and several liability for VAT not paid by the supplier.
In particular, joint and several liability will also be extended to certain categories of services identified in the new Annex 16 to the VAT Law, including accounting and administrative, advertising and market research services. Companies providing or purchasing such services should analyse the new provisions in advance and assess their effects on contractual relationships, supplier verification procedures and tax risk management.
Simplifications provided for transaction costs above PLN 15,000
In September 2026, the Polish Sejm approved a package of deregulation measures for businesses that, according to the reference material, is expected to enter into force on 1 January 2027. One of the planned changes concerns the elimination of the tax penalty that involves the exclusion from deductible costs for PIT and CIT income tax purposes of certain transactions exceeding PLN 15,000, if the payment is made to a bank account not indicated in the so-called white list of VAT taxpayers or without applying the split payment mechanism, where relevant.
The package also includes changes to the way TPR information is signed up for transfer pricing information and simplifications for micro and small enterprises with regard to the disclosure of certain financial indicators.
As the provisions were still awaiting completion of the legislative process at the date of the reference material, it will be necessary to check their final text and the actual date of entry into force before applying them.
Reimbursement of sickness contributions by the ZUS: tax clarifications
The Polish Ministry of Finance has clarified the tax treatment of sickness contributions returned by the ZUS to entrepreneurs.
The treatment depends on how the contributions were originally accounted for: if deducted as tax-relevant costs, the refund generally involves an adjustment of the costs in the period in which the reimbursement or compensation by the ZUS takes place. If, on the other hand, they were deducted from income or revenues, the amounts refunded must be added according to the applicable rules in the declaration relating to the year in which the refund was received.
The entrepreneurs concerned should verify the original tax treatment of the contributions to ensure the correct accounting of the sums returned.
Medical certificates for preventive examinations of workers: transition to electronic format
From 18 October 2026, medical certificates relating to preventive examinations of workers will have to be issued exclusively in electronic format. This will end the transitional period during which paper issuance was still allowed.
Employers and human resources managers should ensure that internal procedures are adapted to the new system of issuing and transmitting medical records.
IC&Partners Poland S.A.
Plac Powstańców Warszawy 2a
00-030 Warszawa
Tel: +48 22 828 39 49
Fax: +48 22 827 78 91
info@icpartnerspoland.pl
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