Poland will implement a mandatory electronic delivery system (e-Doręczenia) for businesses and trusted professions by 2026, replacing traditional paper correspondence.
What is an Electronic Delivery Address (ADE)?
According to Article 2, point 1 of the Act of November 18, 2020, on electronic delivery, an electronic delivery address (ADE) is an email address registered in the electronic address database, assigned to an entity using a public or qualified registered electronic delivery service. It enables unambiguous identification of the sender or recipient of data transmitted within these services.
The Formal-Legal Character of the Electronic Delivery Address
An electronic delivery address has a specific formal and legal character. It is an element of the state’s telecommunications infrastructure with an official and evidentiary nature.
Legal Effects of Registering an Address in the Electronic Address Database (BAE)
Registration of an address in the Electronic Address Database (BAE), according to Article 7 of the Act, is crucial for the effectiveness of deliveries. Specifically, it establishes a legally recognized point of contact for official communications.
In practice, this means that delivery is considered complete upon receipt at the ADE, even if the recipient does not actively acknowledge it, mitigating the risk of “fictitious delivery.”
Who Must Have e-Delivery in 2026?
The obligation to use the e-Delivery system varies depending on the entity’s status, encompassing both public and certain non-public entities.
A mandatory e-delivery obligation applies to public bodies, lawyers, legal advisors, notaries, and other trusted professions. It also applies to new entities registered in the National Court Register (KRS) from 2025.
Who is Exempt from Using e-Delivery?
The e-Delivery system is not universally mandatory for all legal entities. The legislator has clearly distinguished between obligated entities and those who can use the system voluntarily.
Individuals not practicing a profession or with suspended qualifications are exempt. Individuals not engaged in business activity are generally not required to have an electronic delivery address.
Voluntary Use of ADE
Entities not legally obligated can voluntarily create an electronic delivery address. Both individuals and other non-public entities can choose to join the e-Delivery system on their own initiative.
e-Delivery Implementation Schedule
The implementation schedule is based on official information published by the government administration on the gov.pl portal.
The schedule outlines when e-Delivery becomes mandatory for different groups of entities, adopting a phased approach starting with public administration, then businesses, and finally selected public trust professions.
How to Create an Electronic Delivery Address and When Does the Obligation Arise?
The Act provides two ways to create an electronic delivery address: through application or automatically.
Automatic address assignment aims to ensure the universality of the system and reduce the formal obligations of entrepreneurs.
e-Delivery and ePUAP – Will They Replace Existing Systems?
The e-Delivery system is intended to take over the correspondence function of the ePUAP platform. Communication with public administration will primarily be conducted via an electronic delivery address. However, ePUAP will not be immediately discontinued; its remaining functionalities will be gradually replaced through other digitization projects.
Summary
From the perspective of conducting business activity, failing to implement e-Delivery in 2026 is not just an organizational issue but a real legal and business risk.
FAQ – Frequently Asked Questions
The obligation to use e-Delivery primarily applies to public entities and selected non-public entities, including businesses and representatives of public trust professions.
Non-public entities are subject to the obligation in phases, with some required to comply upon registration, while existing businesses have later deadlines.
For individuals not engaged in business activity, using e-Delivery is voluntary.