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The European Union has adopted a common maximum limit for cash payments involving businesses. This article explains Poland’s domestic payment-account requirement and the EU rules that will apply from 10 July 2027.
Poland’s payment-account requirement: transactions above PLN 15,000
Article 19 of the Entrepreneurs’ Law requires a business to make or receive payment through a payment account when the other party is another entrepreneur and the single transaction value exceeds PLN 15,000 or its equivalent.
The threshold concerns the value of the transaction, irrespective of how many payments result from it. Dividing the amount into instalments does not remove the obligation.
Article 15d of the CIT Act and Article 22p of the PIT Act provide tax consequences for non-compliance. The part of an expense paid without a payment account in breach of the requirement cannot be deducted as a tax cost. If it has already been deducted, the taxpayer must reduce costs or, where appropriate, increase revenue.
A proposal to increase the Polish threshold
The original article describes a parliamentary proposal submitted on 16 April 2026 to amend the Entrepreneurs’ Law and the VAT Act. It proposed raising the professional-transaction cash threshold from PLN 15,000 to PLN 25,000, citing the erosion of its purchasing power after years of inflation.
At the stage described in that article, public consultation had ended on 17 May 2026 and the proposal had not yet received a parliamentary print number. A proposed PLN 25,000 threshold must not be treated as enacted law merely because the proposal was submitted. Its subsequent legislative status should be checked separately.
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The EU’s EUR 10,000 maximum from 10 July 2027
Separately from Polish proposals, Regulation (EU) 2024/1624 of the European Parliament and of the Council of 31 May 2024 introduced a common maximum for cash payments as part of the anti-money-laundering framework. The relevant rules apply from 10 July 2027.
The EUR 10,000 ceiling concerns persons trading in goods or providing services. It covers both business-to-business transactions (B2B) and sales to consumers (B2C), including linked transactions. Its scope is therefore broader than Poland’s Article 19 requirement, which concerns transactions between entrepreneurs.
The regulation contains exceptions, including payments between individuals acting outside a professional capacity, and specific treatment of payments or deposits at financial institutions. The precise circumstances should be checked before applying an exception.
Does the EU ceiling replace Poland’s lower threshold?
No automatic increase of Poland’s domestic B2B limit follows from the EU ceiling. Member States may retain or introduce lower limits, subject to the applicable consultation with the European Central Bank and notification of the European Commission.
Consequently, a Polish limit of PLN 15,000 can coexist with the wider EU maximum. A PLN 25,000 domestic limit would require the relevant Polish legislation to be adopted. Businesses should distinguish the existing payment-account obligation from the EU prohibition on cash payments above its maximum.
Before accepting a large cash payment, identify the transaction’s total value, whether the counterparty acts as a business or consumer, whether several operations are linked and which rules apply on the payment date.
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Summary
The EU ceiling does not give Polish businesses permission to ignore a lower national threshold. The Polish B2B payment-account requirement and the broader EU cash restriction have different scopes. Planning should use the enacted rules, transaction totals and effective dates, rather than a proposed increase.
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