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Unregistered Businesses Face KSeF Mandate in 2026, With Revenue-Based Exceptions

Poland’s National e-Invoicing System (KSeF) will become mandatory for unregistered businesses in 2026, but a new quarterly revenue limit and client type exemptions apply.

Unregistered Business Activity Explained

Unregistered (non-registered) business activity is a form of small-scale income-generating activity that can be legally conducted without registration in the Central Register of Information on Economic Activity (CEIDG) or the National Court Register (KRS).

This means the possibility of earning money without the obligation to pay advance income tax and monthly social security contributions (ZUS).

Conditions for Unregistered Activity in 2026

To legally engage in unregistered business activity, certain conditions must be met.

Important Note: 60-Month Rule

Individuals must not have engaged in business activity for the past 60 months to qualify for unregistered activity.

New Quarterly Revenue Limit for 2026

The maximum revenue from unregistered activity in 2026 is 10,813.50 zł per quarter, a significant increase from the previous monthly limit of 3,499.50 zł (75% of the minimum wage).

This allows for greater flexibility, with the possibility of earning more in one month of the quarter than in others, as long as the total quarterly income remains within the limit.

Revenue Limit Warning: 7-Day Response Window

Businesses operating in this form must monitor revenue limits closely. Exceeding the limit requires registration with CEIDG within 7 days.

Record Keeping Requirements

Although not subject to income tax advances or ZUS contributions, unregistered businesses must maintain a record of income, including all sources.

KSeF and Unregistered Businesses: The April 2026 Mandate

From 2026, the National e-Invoicing System (KSeF) will be mandatory for most entrepreneurs in Poland.

However, businesses with a total gross sales value from invoices of less than 10,000 zł per month may postpone KSeF implementation until 2027.

KSeF for Unregistered Activity: Who Can Avoid Online Invoices Until 2027?

KSeF also applies to unregistered businesses, with certain exceptions. They may be unaware of their obligation to issue invoices in KSeF from April 1, 2026, requiring early system implementation.

KSeF Obligation Depends on Client Type

The obligation to use KSeF depends on the type of customer.

KSeF Obligation Chart

Type of Sale / Client | Is KSeF Mandatory? | Effective Date

Sales to businesses (B2B) with revenue above 10,000 zł monthly | Yes | April 1, 2026

Sales to businesses (B2B) with revenue up to 10,000 zł monthly | Yes | January 1, 2027 (possible transition period until end of 2026)

Sales to consumers (B2C) (private individuals) | No | –

Important: Receiving KSeF Invoices

Unregistered businesses must be prepared to receive invoices from suppliers using KSeF from February 1, 2026, if their counterparty is obligated to use the system.

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