What changes will come into force for unregistered businesses in 2026?

From 1 January 2026, unregistered business activity in Poland will undergo a significant transformation, which will change the approach to tax accounting for small businesses. The most important change involves moving away from a monthly revenue limit in favour of quarterly tax returns. In practice, this means that instead of having to keep an eye on the limit every month, you can plan your revenue more flexibly, with a limit of 225 per cent of the minimum wage available to you each quarter. With the minimum gross wage set at 4,806 zł, the quarterly limit will amount to exactly 10,813.50 zł. This change is primarily intended to accommodate those who work seasonally, engage in occasional sales or carry out irregular commissions.

As Piotr Juszczyk, chief tax adviser at inFakt, emphasises:

“The new quarterly limit for unregistered business activity is a long-awaited solution for people with irregular incomes. The previous monthly threshold excluded those who do not earn anything for several months and then experience a larger influx of cash.”

In 2025, the monthly limit stood at 3,499.50 PLN. Many craftspeople, tutors, tour guides and small-scale service providers had to spread their work throughout the year to avoid exceeding the monthly threshold. From 2026, a single large commission or a busy season will no longer require you to register a business, provided that your revenue does not exceed 10,813.50 PLN in any given quarter.

Who can carry out unregistered business activity in 2026?

The basic conditions remain unchanged. Only individuals who meet the following criteria may operate an unregistered business in 2026:

• have not carried out any business activity for the past 60 months (5 years),
• have not exceeded the quarterly revenue limit (PLN 10,813.50 per quarter),
• do not carry out activities requiring a licence, authorisation or entry in the register of regulated activities (e.g. legal, medical, brokerage, transport or accountancy services),
• do not employ staff under employment contracts (civil-law contracts are permitted in certain situations).

A new development from June 2025 is the introduction of restrictions for foreign nationals – only those holding a residence permit entitling them to register a business in Poland may carry out unregistered business activities. Minors may also use this form of business, provided that the specific type of business in question does not require full legal capacity.

It is worth bearing in mind that suspending business activity for 60 months is treated as equivalent to not carrying out any business activity at all – so if someone has had their sole trader business suspended for the last 5 years, they can now make use of unregistered business activity.

How do you calculate the revenue limit for unregistered business activity?

It is crucial to distinguish between revenue due (which counts towards the limits) and revenue received (to be declared for tax purposes on the PIT-36 form). The quarterly limit of 10,813.50 zł covers all revenue due – including that which has not yet been credited to your account but arises from invoices or bills issued. The value of returned goods, discounts granted or rebates is not included in the limit.

Practical example: if you earn PLN 8,000 in one month, and PLN 1,400 and PLN 1,400 in the following two months, the total for that quarter is PLN 10,800 – you remain within the limit and do not need to register your business. Exceeding the limit by even one zloty in any quarter means you must register your sole trader business with CEIDG within 7 days.

There is also a so-called ‘grace period’ rule – if you have previously run a business, you may only resume unregistered business activity 60 months after the termination or suspension of your sole trader business.

How do you keep records and settle taxes when operating as an unregistered business?

If you are running an unregistered business in 2026, you do not need to keep full accounts. However, simplified sales records are mandatory – you can keep these in a notebook, a spreadsheet or an accounting programme. It is important to note the date of the transaction, a description, the amount of income and the cumulative total for the quarter. Example entry:

Example of a record:

01.02.2026 | Korepetycje – Jan Kowalski | 200 zł | 200 zł
05.02.2026 | Sprzedaż rękodzieła online | 400 zł | 600 zł
15.03.2026 | Grafika – projekt logo | 1000 zł | 1600 zł
31.03.2026 | SUMA I kwartał | 1600 zł

Keeping a record allows you to monitor your income on an ongoing basis and quickly identify when you are approaching the limit. At the end of the tax year, you declare income from unregistered business activity on the PIT-36 form, under the heading ‘unregistered business activity’. You pay tax according to the tax scale (12% or 32%), taking into account tax-deductible costs and the tax-free allowance (30,000 zł).

You do not need to make monthly tax advance payments – you settle everything once a year. A customer may request an invoice or receipt (within 3 months of the end of the month in which the sale took place), which you must issue. An invoice can be issued without a tax identification number (NIP), provided you state your first name, surname and address.

Do you have to pay social security contributions (ZUS) when running an unregistered business?

The absence of an obligation to pay ZUS contributions is one of the greatest advantages of running an unregistered business. You do not pay pension, sickness, accident or health insurance contributions – unless you are providing services under a contract for services, in which case the client registers you for insurance and pays the contributions. If you have no other means of health insurance cover, you can voluntarily register with the National Health Fund (NFZ) – the contribution is approximately 9 per cent of the average wage, which in the fourth quarter of 2025 amounts to 796.91 zł per month. For most small business owners, however, this is an uneconomical cost, which is why many people opt for unregistered self-employment as a way of earning extra money alongside a full-time job, an employment contract or a contract of service.

If you exceed the limit and switch to a sole trader (JDG) status, you can benefit from the start-up relief for the first 6 months (paying only the health insurance contribution), followed by 36 months under the ‘Mały ZUS Plus’ scheme.

Who is not eligible for unregistered business activity?

Not every type of business activity can be carried out without formal registration. In 2026, unregistered business activity excludes:

• regulated activities (e.g. legal, medical, transport, accountancy, tax consultancy and insurance brokerage services),
• all activities requiring a licence, permit or entry in the register of regulated activities,
• the employment of staff under an employment contract (civil-law contracts without a permanent position are permitted),
• activities requiring VAT registration once the threshold is exceeded (from 2026: PLN 240,000 per year),
• certain types of online sales (e.g. jewellery, consultancy services, sales of electronics – VAT registration is always mandatory regardless of turnover).

Unemployed persons, in order not to lose their status, may not carry out unregistered business activities under civil law contracts (contracts for specific work or contracts for services) – they may only sell goods. Minors are subject to restrictions arising from specific age-related regulations.

How do you deal with VAT, the cash register and other formal obligations?

When running an unregistered business, you can benefit from a VAT exemption based on your status – the limit will rise to 240,000 zł per year in 2026. Bear in mind that certain sectors are excluded from the right to exemption (e.g. legal services, jewellery, consultancy, and online sales of electronics). If you sell goods or services to private individuals and your turnover did not exceed PLN 20,000 in the previous year, you do not need to have a cash register – with the exception of sectors that are always required to record sales on a cash register (e.g. hairdressing, beauty treatments, catering, and vehicle repairs).

You are also obliged to comply with consumer rights: you must allow returns, deal with complaints and provide information on the terms and conditions of sale. In your dealings with customers, you are treated as a trader, even if you do not have a formally registered business.

Sales via online platforms are also subject to reporting to the National Tax Administration under the DAC7 Directive if you exceed 30 transactions or €2,000 in annual revenue.

What does running an unregistered business look like in practice?

The introduction of quarterly limits offers considerable flexibility. Here are a few typical examples:

1. An English tutor – Anna earns 2,500 zł a month for most of the year, but in May and June there is increased demand for her services. Until now, she had to limit the number of pupils so as not to exceed the monthly limit. From 2026, she will be able to earn as much as 6,000 PLN in one month and 4,498.50 PLN in another without losing her right to carry out unregistered business activity.
2. Christmas tree decoration seller – Marek makes all his sales in November and December, often exceeding the monthly limit. He can now earn 10,498.50 zł in the fourth quarter.
3. Tour guide – Kasia concentrates her work during the peak summer season, taking advantage of high rates in July and August without worrying about the monthly limit.
4. Freelance graphic designer – Tomek undertakes large projects and is paid in a single instalment. He can issue an invoice for 8,000 PLN in one month, have no income in the other months, and continue to operate as a self-employed person without registration.

Thanks to the new regulations, unregistered business activity is accessible to people testing a business idea, freelancers, craftspeople, seasonal service providers or students wishing to earn extra money legally without the risk of high costs and excessive red tape.

What should you do if you exceed the limit? How do you switch to a sole trader business?

Exceeding the quarterly limit of 10,813.50 PLN results in your unregistered business being automatically converted into a sole trader business. You then have 7 days to register with the CEIDG. Registration brings with it certain obligations: selecting PKD codes, making a decision regarding VAT (you can continue to benefit from the exemption if you have not exceeded the PLN 240,000 limit), paying ZUS contributions and making regular advance payments towards income tax. A newly registered entrepreneur can take advantage of the start-up relief (6 months without social security contributions) and the ‘Mały ZUS Plus’ scheme (36 months of reduced contributions, provided your annual revenue does not exceed PLN 120,000).

Exceeding the limit is not a failure, but a natural stage in the development of your business – a sign that your idea is working and that it is worth moving to a higher organisational level.

What are the most common mistakes when running an unregistered business, and what should you watch out for?

The most common mistakes include a lack of knowledge about current limits, incorrect recording of income and expenses, failure to keep sales records, and failure to report exceeding the limit on time. Remember that the tax office and ZUS may audit your records – if you do not keep records or keep them inaccurately, you risk a fine, having to pay outstanding taxes and contributions, and even financial penalties.

Failure to comply with consumer rights (e.g. lack of information on returns, refusal to accept complaints) carries the risk of proceedings before the Office of Competition and Consumer Protection (UOKiK) or a civil court.

Failure to distinguish between income due (up to the limit) and income received (for PIT purposes) leads to errors in tax returns. Every transaction should be documented – by an invoice, receipt, contract or bank transfer confirmation.

How can you prepare to run an unregistered business in 2026?

In 2026, it is worth planning your seasonal business activities now and preparing tools for recording revenue. A simple spreadsheet, a dedicated mobile app or accounting software with a function to monitor quarterly limits works best. It’s worth preparing invoice and receipt templates straight away – even if you’re not obliged to issue them, customers may ask for them.

Based on the experience of ‘Firma dla Każdego’, people testing a business idea, freelancers and students often use unregistered business activity as a first step before deciding to set up a fully-fledged sole trader business. Getting started is quick, cheap and allows you to focus on developing your services rather than on red tape. However, if you’re planning to operate on a larger scale or collaborate regularly with larger companies, consider registering your business sooner to avoid unnecessary stress caused by exceeding the limits.

What are the prospects for changes to unregistered businesses after 2026?

The introduction of quarterly limits is a result of calls from small business communities, who have been appealing for greater flexibility for years. Experts predict that the government may further raise the revenue limits, particularly in the context of rising inflation and the cost of living. Simplifications to tax returns, the automation of tax settlements and an expansion of the list of activities permitted without registration are also being considered. On the other hand, we can expect stricter documentation requirements for online sales and greater scrutiny of compliance with turnover limits – particularly in e-commerce, where foreign platforms and reporting to the tax authorities are increasingly common.

If you decide to operate without registration, you should keep an eye on announcements from the Ministry of Development, draft legislation and the views of industry experts, so that you can adapt to changing requirements as they arise.

Please feel free to contact us

If you need professional support regarding unregistered business activities in 2026, please contact Firma dla Każdego. The Foundation’s specialists assist not only those testing their business ideas, but also freelancers and individuals wishing to avoid high social security contributions and complex bureaucracy. You can find details of our services at firmadlakazdego.pl.