Poland: replacement of fiscal memory in older cash registers to be prohibited from July 2027

From July 1, 2027, Poland will prohibit the replacement of fiscal memory in cash registers with electronic copy recording. Businesses using these older devices will have to replace them with online cash registers when their fiscal memory becomes full or fails.

What is changing from July 1, 2027?

Poland is introducing new restrictions on the use of traditional fiscal cash registers as part of its ongoing transition toward online fiscalization.

Under the Act of September 4, 2026, amending the VAT Act and the Act on the Principles of Recording and Identifying Taxpayers and Payers, businesses will no longer be allowed to replace the fiscal memory of cash registers that record electronic copies of receipts.

The legal basis is Article 145a(5) of the Polish VAT Act, as amended by the Act of September 4, 2026. The amendment was published on September 29, 2026, in the Journal of Laws of 2026, item 1270, and the fiscal memory provision takes effect on July 1, 2027: https://dziennikustaw.gov.pl/DU/rok/2026/pozycja/1270 

The restriction will take effect on July 1, 2027, extending an existing prohibition that already applies to cash registers with paper copy recording.

The amendment was published in the Polish Journal of Laws on September 29, 2026, under item 1270. Although the law has a general effective date of January 1, 2027, the specific provision concerning fiscal memory replacement becomes applicable on July 1, 2027.

The objective is to gradually eliminate older cash register models and encourage businesses to use modern online cash registers connected to the tax administration.

Poland has three main categories of fiscal cash registers:

• Cash registers with paper copy recording: Traditional devices that store copies of fiscal receipts on paper. Replacing their fiscal memory is already prohibited.
• Cash registers with electronic copy recording: Older devices that store receipt copies electronically but do not automatically transmit fiscal data to the tax administration. Fiscal memory replacement will become prohibited from July 1, 2027.
• Online cash registers: Modern devices that communicate electronically with the Central Repository of Cash Registers (CRK), allowing fiscal data to be transmitted to the tax administration.

Online cash registers were introduced in Poland on May 1, 2019. Software-based or virtual cash registers became available under regulations effective from June 1, 2020, for permitted uses.

The distinction is important because the new restriction concerns traditional cash registers with electronic copy recording, not modern online cash registers.

Can businesses continue using their existing cash registers?

Yes. The amendment does not automatically require all businesses to replace their existing traditional cash registers on July 1, 2027.

Businesses may continue using older devices with electronic copy recording as long as those devices remain operational, their fiscal memory does not require replacement, and their use is otherwise legally permitted.

However, once the fiscal memory becomes full, fails, or needs replacement for another reason, the cash register can no longer remain in service through a fiscal memory replacement.

For example, if a retailer operates a traditional cash register and its fiscal memory becomes full in August 2027, the retailer will not be permitted to replace that memory and continue using the same device. Instead, the business will need to move to a compliant replacement, normally an online cash register.

Certain sectors are already subject to mandatory online cash register requirements under Article 145b(1) of the VAT Act, including short-term accommodation services. Businesses in these sectors cannot rely on the general permission to continue using traditional devices.

According to the justification accompanying the legislative amendment, the restriction is intended to support the gradual withdrawal of traditional cash registers from the Polish market.

Older devices with paper or electronic receipt copies do not have the same functionality as modern online cash registers, particularly the capability to transmit fiscal information to the Central Repository of Cash Registers.

The CRK enables the Polish tax administration to collect and analyse fiscal transaction data electronically, improving its ability to monitor registered sales and identify potential VAT irregularities.

The new regulation follows the same approach already applied to cash registers with paper copy recording: existing devices are gradually withdrawn when their fiscal memory can no longer be used.

This approach also aligns with Poland's previous restrictions on placing older cash register models on the market. Their gradual replacement has been part of the country's fiscalization strategy since the introduction of online cash registers in 2019.

What does the amendment mean for fiscal device manufacturers and POS providers?

The new restriction is particularly relevant for manufacturers, distributors, service providers and businesses maintaining traditional fiscal cash registers.

Service providers will need to consider the July 2027 deadline when advising customers about maintenance and fiscal memory replacement.

For POS software providers and system integrators, the transition may require coordination between existing POS systems and newly installed online fiscal devices.

Businesses replacing older devices should ensure that their POS software can communicate correctly with the selected online cash register and that applicable fiscalization requirements are met.

Retailers operating multiple locations may face additional challenges, particularly where different stores use cash registers with different levels of remaining fiscal memory capacity.

In ourview, this amendment represents another important step in Poland's transition from traditional fiscal devices toward a more connected and digitally monitored fiscalization system.

Although the regulation does not introduce an immediate obligation to replace every older cash register, it significantly limits the possibility of extending the operational life of these devices.

For retailers, the main challenge will be planning equipment replacement before a fiscal memory failure or capacity limitation interrupts sales operations.

Implementation impact and what the business should do:

The amendment will affect businesses using traditional fiscal cash registers with electronic copy recording, as well as the service providers, manufacturers and POS vendors supporting these devices.

Businesses should take the following actions:

• Identify affected devices: Review all cash registers currently in use and determine whether they use paper copies, electronic copies or online fiscalization.
• Check fiscal memory capacity: Assess whether existing devices are likely to require fiscal memory replacement before or after July 1, 2027.
• Plan equipment replacement: Prepare to replace affected devices with compliant online cash registers when their fiscal memory becomes full or fails.
• Verify POS compatibility: Ensure existing POS software and retail systems can integrate with compliant replacement fiscal devices.
• Coordinate with service providers: Confirm maintenance arrangements and establish procedures for replacing devices that can no longer be used.

The key deadline is July 1, 2027. From that date, replacing fiscal memory in cash registers with electronic copy recording will no longer be permitted. Although businesses are not generally required to replace all such devices immediately, they should prepare for the transition to online fiscalization.

The source for this text above is an article published by Prawo. Source

Nikolina Basić, Senior Legal Consultant at Fiscal Solutions

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