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The general rule is that sales to private individuals must be recorded using a cash register. However, there are several exceptions in the form of exemptions provided for in the Minister of Finance’s Regulation of 17 December 2024 on exemptions from the obligation to record sales using cash registers. In this article, we identify the most important ones.
The general rule — an obligation to record sales using a cash register when selling goods and services to private individuals
Article 111(1) of the VAT Act expressly states: “Taxpayers selling to individuals who do not conduct business activity and to flat-rate farmers are required to keep sales records using cash registers”.
This is the general rule, under which the obligation to keep records using a cash register generally applies to all entrepreneurs selling services or goods to private individuals.
However, there are important exceptions listed in the Minister of Finance’s Regulation of 17 December 2024 on exemptions from the obligation to record sales using cash registers.
A taxpayer-based exemption from having a cash register in 2026 — the PLN 20,000 limit for sales to private individuals
The first possible exemption from a cash register, applicable until 31 December 2027, concerns taxpayers whose sales to individuals not conducting business activity and to flat-rate farmers in the previous tax year did not exceed PLN 20,000.
It should be noted that sales to business customers are not included in this limit, and entrepreneurs who established their business during the year calculate it proportionally to the period of business activity in that year.
This exemption is not available to taxpayers who were already required to record sales using a cash register in the previous tax year, or to taxpayers who ceased to meet the conditions for the exemption.
It is also worth noting that after exceeding this limit, the entrepreneur has as much as two months to introduce a cash register in their business. Under the applicable rules, the exemption expires only after two months, counted from the end of the month in which the limit was exceeded.
Another way to qualify for a cash register exemption? Bank transfer payments and other activities listed in the regulation’s annex which allow an exemption
In addition to the exemption based on the limit for sales to private individuals described above, the Minister of Finance’s Regulation of 17 December 2024 provides for another important exemption.
This is addressed specifically in Section 2(1) of the regulation, which states: “The activities listed in the annex to the regulation are exempt from the obligation to keep records in a given tax year, but no later than until 31 December 2027”.
Since the annex includes as many as 58 items, we list only the most important activities below:
- Providing services to individuals not conducting business activity and to flat-rate farmers, where full payment is received into a bank account or an account at a cooperative savings and credit union, and the records and payment evidence clearly identify the specific activity to which payment relates;
- Supplying goods by mail order, where full payment is received into a bank account or an account at a cooperative savings and credit union, and the records and payment evidence clearly identify the specific activity and the person for whom it was performed;
- Supplying electricity and gas;
- Services relating to water treatment and supply;
- Postal and courier services;
- Telecommunications services;
- Financial and insurance services;
- Real estate services, where the services are fully documented by an invoice;
- Notarial activities;
- Certain educational services;
- Services provided by organisations, membership organisations and extraterritorial bodies;
- Supplying real estate;
- Leasing land and granting perpetual usufruct rights to land;
- Selling air travel tickets, meals and goods aboard aircraft.
This shows that the second type of exemption concerns supplies of selected goods, provision of certain services and sales relating to particular activities.
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Without doubt, the most widely applicable basis for this exemption is supplying goods by mail order or providing services to individuals not conducting business activity and to flat-rate farmers where all the following conditions are met:
- Full payment for the goods or service reaches the seller’s bank account or their account at a cooperative savings and credit union;
- The records and evidence documenting payment clearly identify the specific activity, meaning the goods or service, to which the payment relates and, for mail-order supplies, also the exact person for whom the supply was made.
When does the cash register exemption not apply in 2026?
Section 4 of the Regulation of 17 December 2024, already cited several times in this article, identifies situations in which the above exemptions cannot be used.
Again, the list is very long, but we draw particular attention to:
- Supplies of liquefied gas;
- Supplies of engine parts and engines for vehicles and motorcycles;
- Supplies of bodies, trailers, containers, parts and accessories for selected motor vehicles;
- Supplies of desktop and portable computers, games consoles and their parts, and other electronic products specified in the regulation;
- Supplies of optical products and photographic equipment;
- Supplies of tobacco products and alcoholic beverages with alcohol content above 1.2%, as well as perfumes and eau de toilette, excluding goods supplied aboard aircraft;
- Taxi services;
- Repair of motor vehicles and mopeds, tyre and wheel replacement, and vehicle technical tests and inspections;
- Tax advisory and legal services, except notarial activities covered by a separate exemption;
- Hairdressing, beauty and cosmetology services;
- Certain cultural, entertainment and recreational services;
- Vehicle washing and cleaning services;
- Car park operations.
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Summary
Recording sales using a cash register in 2026 — the obligation and possible exemptions
Although the general rule is that every sale to private individuals must be recorded using a cash register, the Minister of Finance’s Regulation of 17 December 2024 on exemptions from the obligation to record sales using cash registers provides widely used exemptions.
One exemption concerns cases where annual sales to individuals not conducting business activity and to flat-rate farmers do not exceed PLN 20,000.
The second route to an exemption concerns activities expressly listed in the regulation’s annex. Among its 58 items, the two most important and widely applicable undoubtedly concern mail-order supplies of goods and services provided to individuals not conducting business activity and to flat-rate farmers — both with full payment into a bank account or credit union account, and records and documents clearly identifying the activity to which the payment relates.
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