The Ministry of Finance has officially announced that exemptions from cash registers will continue to apply in 2025. The draft regulation, which was released in August 2024, maintains the exemption limit at PLN 20,000 and introduces minor changes to the list of activities exempt from the obligation to use cash registers.

The draft regulation, which outlines exemptions for 2025, reflects changes and regulations effective for 2025-2026. The final version is expected by the end of the year, as the current regulation from November 24, 2023, is only valid until the end of 2024. Without a new regulation, all transactions would need to be recorded on a cash register from the first sale, as per Article 111, Section 1 of the VAT Act. This would affect the supply of goods and services to individuals and flat-rate farmers. The draft maintains the current exemption limit at PLN 20,000 for 2025 and 2026. This limit applies to both new and continuing businesses. For businesses starting sales during the year, the exemption limit is calculated proportionally.

The activities listed in § 4 of the regulation must be recorded on the cash register regardless of the taxpayer's turnover. They are not subject to, among other things, the subjective exemption.

The draft of the new regulation shows that the Ministry of Finance plans to expand the scope of these activities. The following are to be added:

Deliveries:

1. a) products classified under CN 2404 and 8543 40 and hemp products (genus: Cannabis) classified under CN 1211, intended for smoking or inhalation without combustion,
2. b) products containing ethyl alcohol with a strength by volume exceeding 50%, not intended for human consumption, including solvents, disinfectants, paint thinners, de-icing fluids,
3. c) coal, briquettes, and similar solid fuels produced from coal, brown coal, coke, and semi-coke, intended for heating purposes,
4. d) goods using automatic sales devices that accept payment and issue goods in an unattended system.

Provision of services:

1. a) parking of cars and other vehicles,
2. b) using devices, including ticket-issuing devices, operated by the customer, which also accept payment in coins or banknotes in an unattended system or in another form (cashless), other than car washing, cleaning, and similar services (PKWiU 45.20.30.0), which are already covered by the absolute obligation to record.

The annex to the regulation lists the activities exempt from the cash register objectively. In principle, from 1 January 2025, this list will not undergo any fundamental changes. However, exemptions for:

1. delivery of goods using automatic sales devices that accept payment and issue goods in an unattended system,
2. provision of services using devices, including ticket issuing devices, operated by the customer, which also accepts payment in an unattended system in:
3. a) coins or banknotes, or
4. b) in another form (non-cash), if the records and evidence documenting the payment or activity indicate what specific activity the payment concerned,

In the current legal status, the above activities are included in items 39 and 40 of the annex to the regulation.

The draft includes a new item of subject exemption. This is the supply of goods and services by taxpayers not established in Poland who benefit from the subject exemption from VAT (so-called EU subject exemption) based on Article 113a of the Act. The introduction of this exemption is related to Council Directive (EU) 2020/285, which is to be implemented into the national legal system by 31 December 2024 and apply from 1 January 2025.