On 6 July 2026, the Minister for Supervision of the Implementation of Government Policy, Maciej Berek, and the Minister of Finance and Economy, Andrzej Domański, presented a package of changes to the tax system referred to as “Deregulation 2.0”. The aim of the proposed solutions is to simplify tax settlements and improve relations between the tax administration and taxpayers and entrepreneurs. The project is the result of extensive public consultations, during which all submitted proposals were analysed. As Minister Domański emphasized, the reform is to be based on four pillars: certain tax rulings, the extension of the principle of tacit consent, clear and legible procedures for contacting the administration, and the further use of digitization to facilitate business activity.
One of the most practical of the proposed changes is the resignation from the obligation to have a physical cash register in favor of a simple, free application installed on any mobile device, used to issue receipts. This solution is to reduce “paperwork” and costs of running a business, and customers will be able to receive a receipt with a QR code or an e-receipt instead of a paper document. Traditional fiscal cash registers – both hardware and virtual online – will remain available to taxpayers for whom such a settlement model will be more suitable. At the same time, the popularization of e-receipts is to enable the tax administration to prepare a pre-filled VAT return for the taxpayer, ultimately covering about 2 million VAT taxpayers, who will decide on their own whether to use this solution; In this case, it is enough to verify the data and approve the sending of the declaration.
An important change from the perspective of the current tax security of enterprises is the introduction of a mechanism of reduced interest when adjusting the settlement on their own. The system is supposed to independently detect and signal errors in settlements, and a taxpayer who corrects the declaration before the office reacts will pay only half of the interest due and avoid fiscal penal consequences. An analogous, reduced interest rate will also apply to taxpayers who are late with submitting the first return, but submit it themselves and pay the tax without prior request from the authority.
The reform is also to introduce significant changes in the scope of individual tax rulings. Currently, about 25 thousand such rulings are issued annually, and the total number of them has already exceeded half a million, which makes it significantly more difficult to determine which of them are still in force. The new regulations introduce a five-year validity period for an individual tax ruling, while the administration will be obliged to ensure that it is up-to-date – if the legal status does not change, the validity of the tax ruling will be automatically extended. If, on the other hand, the authority changes the ruling during its validity, the taxpayer who complied with it will not be obliged to pay the overdue tax. The role of general tax rulings will also be strengthened – the taxpayer will not suffer negative consequences resulting from a change in such an interpretation by the administration, even though today a change in the general tax ruling may be associated with the need to pay tax retroactively. A similar mechanism of legal certainty will apply to local taxes: currently, tax rulings on real estate tax will be issued by nearly 2500 municipalities, each according to its own practice, while after the introduction of the changes, uniform interpretations applicable throughout the country will be issued by one authority, thanks to which an entrepreneur owning real estate in several municipalities will submit only one application.
The principle of tacit consent will be significantly expanded. In the case of natural persons, it will include applications for postponement of the tax deadline or remission of the costs of proceedings – if the office does not respond within the statutory deadline, the case will be resolved in favor of the taxpayer. The same rule will apply to applications for restoration of the deadline for reporting the acquisition of an inheritance or donation. According to Minister Domański’s announcement, this solution is to enter into force in the first quarter of 2027. The tacit consent will also be extended to procedural matters concerning entrepreneurs – the lack of a reaction of the office within the deadline will mean that applications for m.in restoration of the deadline, extension of the accepted security, suspension or commencement of suspended proceedings, as well as withdrawal of the appeal will be positively considered.
The package also provides for the introduction of the materiality principle, according to which the authority will not initiate proceedings in the case of frivolous transactions with minimal impact on public finances; the exception will be situations of deliberate action to the detriment of the State Treasury. In the field of real estate tax, the co-owner will no longer be liable for the entire tax liability, but only in proportion to the share held, which means the end of the current practice of collecting the full amount of tax from one of the co-owners.
The changes will also include the appeal procedure and verification activities carried out by tax authorities. The deadline for filing an appeal against a tax decision will be extended from 14 to 30 days – in 2025 alone, taxpayers filed 6.5 thousand appeals, and the previous deadline was often not even enough to collect the necessary documentation. Taxpayers will also have the right to waive their right to appeal, which will allow for immediate enforcement of the decision without having to wait for the appeal deadline to expire. With regard to verification activities, currently carried out on the scale of approx. 2.5 million per year, a clear, time-limited framework will be introduced – taxpayers will receive precise information about the date of commencement and completion of such activities, which will eliminate the current practice of unlimited verification of settlements. The tax authority will be able to call the taxpayer only for those documents that cannot be downloaded automatically from the administration’s ICT systems. A taxpayer who complies with the findings made in the course of the verification activities will gain protection against the calculation of interest for late payment and against the initiation of criminal fiscal proceedings in this regard.
Beneficial changes will also apply to taxpayers in a difficult payment situation. A taxpayer paying arrears in installments or as part of an arrangement with creditors will receive a certificate of non-arrears despite the ongoing repayment, which will allow them to use such a document, e.g. in a tender procedure or in a loan application – in 2025 alone, about 4500 restructuring proceedings have been announced, the participants of which will benefit from this solution.
The catalogue of tax securities will also be modernised, which will be extended to include a compulsory mortgage and a pledge on shares, shares and movable property – instead of blocking a bank account, an entrepreneur will be able to choose the form of collateral that is least burdensome for the business. Any decision to secure a tax liability before a final decision is issued will be subject to full verification by an appellate body or a court. The reform also provides for the extension of the institution of binding tax information, previously known from VAT and excise duty, to income taxes – PIT and CIT – under one common procedure, which is to provide taxpayers with certainty about the tax classification of their activities.
The presented “Deregulation 2.0” package therefore includes a wide range of changes in the Tax Ordinance and related regulations, concerning both current recording and settlement obligations, as well as the taxpayer’s relationship with the tax administration at the stage of interpretation, audit, appeal and security proceedings. Some of the solutions, including the extended tacit consent rule for individuals, are expected to enter into force in the first quarter of 2027, as announced; Other changes will be implemented as part of further legislative work.
