The Polish e-commerce market maintains a regular growth rate every year. According to data from the Polish Chamber of Commerce, it closed 2025 with a turnover of nearly PLN 92 billion. At the same time, due to the low entry threshold, every year many entrepreneurs make attempts to break through to customers with their goods. When conducting mail order sales to consumers, do you have to record sales at the cash register?
As indicated in Article 111 sec. of the Polish VAT Act, taxpayers making sales to natural persons who do not conduct business activity and flat-rate farmers are obliged to keep records of turnover and amounts of tax due using cash registers.
In other words, as a rule, when a taxpayer makes a sale to natural persons who do not conduct business activity, such a sale should be registered at the cash register. However, there are exceptions to this.
The Minister of Finance, in the Decree on exemptions from the obligation to keep records of sales using cash registers, specifies that taxpayers are exempt from such records:
- in the case of which the turnover for natural persons not conducting business activity and flat-rate farmers did not exceed PLN 20,000 in the previous tax year, and in the case of taxpayers commencing the supply of goods or services to natural persons not conducting business activity and flat-rate farmers in the previous tax year, if the turnover on this account did not exceed, in proportion to the period of performance of these activities in the previous year tax payment, the amount of PLN 20,000;
- commencing after 31 December 2024 the supply of goods or services to natural persons not conducting business activity and flat-rate farmers, if the turnover anticipated by the taxpayer on this account does not exceed, in proportion to the period of performance of these activities in a given tax year, the amount of PLN 20,000.
And what if the above-mentioned turnover is exceeded in mail order sales?
From the perspective of this type of activity, item 41 of the annex to the above-mentioned Decree is crucial, which indicates that the delivery of goods in the mail-order system (by post or courier) is also exempt if the supplier of the goods receives full payment for the activity performed via the post office, bank or cooperative savings and credit union (respectively to the taxpayer’s bank account or to the taxpayer’s account in a cooperative savings and credit union, of which he is a member), and the records and evidence documenting the payment clearly show what specific activity it concerned and for whose benefit it was performed (the buyer’s data, including his address).
Thus, in practice, in order for a given transaction to be considered a mail order sale, the following conditions must be met:
- the goods will be delivered in the shipping system via post or courier services;
- payment for the goods must be made in full via the post office, bank or cooperative savings and credit union (respectively to the taxpayer’s bank account or to the taxpayer’s account in the cooperative savings and credit union of which the taxpayer is a member);
- the records and evidence documenting the payment must clearly indicate what specific activity the payment related to and for whose benefit it was made;
- The subject of the delivery is not the goods listed in § 4 of the above-mentioned Decree.
Activities that will not benefit from the exemption from the need to register them at the cash register, even when selling them by mail, will be deliveries m.in. (list of goods for example):
- engine parts,
- computers,
- optical products,
- photographic equipment,
- tobacco products.
In order to benefit from the above-mentioned exemption, it is also important that the delivery must take place by post or courier – neither personal collection nor shipment by another logistics company meets the requirements of the regulation. The above is indicated, for example, by the individual ruling of the Director of the National Tax Information of 25 January 2024 (file ref. no. 0114-KDIP1-3.4012.646.2023.2.JG).
To sum up, in a situation where domestic sales are made in the mail-order system (Allegro or Amazon), deliveries are made (by post or courier), payment will be made by bank transfer, and the records and evidence documenting the payment clearly show what specific activity it concerned and for whose benefit it was made (the buyer’s data, including his address, there is no need to record such sales at the cash register). This exemption applies even if the turnover exceeds PLN 20,000.00.
