Poland introduces new fiscal cash register deregistration obligations and PLN 300 penalty from 2027

Poland has introduced new requirements for deregistering fiscal cash registers under amendments to its Value Added Tax (VAT) Act. This will take effect on January 1, 2027.

The amendment clarifies the obligations of retailers and other taxpayers when they permanently stop using a fiscal cash register, whether because they are closing their business or withdrawing an individual register from operation. It can be analyzed by different regulations:

• https://podatki.gov.pl/podatki-firmowe/vat/poradniki-i-informatory/ewidencja-sprzedazy-z-wykorzystaniem-kas-rejestrujacych?utm_.com 
• https://eli.gov.pl/eli/DU/2026/1270/ogl?utm.com 

Under the updated rules, businesses must complete the required procedure for ending the use of the fiscal cash register, protect the fiscal data stored in the device, and submit an application to deregister the register with the competent tax office within the prescribed deadline.

The most important change is the introduction of an explicit PLN 300 financial penalty for failing to submit the deregistration application on time.

The new provisions are introduced through Article 1(26) of the Act of September 4, 2026, which amends Article 111(3a)(13), adds Article 111(6kb), and revises Article 111(6l) of the VAT Act.

What is the deadline for deregistering a fiscal cash register?

The amendment does not establish a fixed number of days for submitting the deregistration application. Instead, it refers to the deadline established by the applicable implementing regulations.

Under the existing Regulation of the Minister of Finance of June 25, 2025, retailers generally must submit the deregistration application together with the required fiscal memory reading report and service protocol within five days of preparing those documents.

For online fiscal cash registers, the closure process generally includes preparing the final daily fiscal report, arranging the fiscal memory reading with an authorized service technician, preparing the required documentation, and protecting the data stored in the register.

Businesses must also ensure that data from the protected memory of online fiscal registers is read and saved to an external storage medium.

The applicable procedure may differ depending on the type of cash register and whether its fiscal memory can be read successfully.

Retailers should therefore follow the relevant implementing regulations and confirm which procedures and deadlines apply when withdrawing their devices.

What happens if a retailer misses the deregistration deadline?

From January 1, 2027, the competent tax authority will impose a PLN 300 financial penalty when a taxpayer fails to submit the required deregistration application within the prescribed deadline.

The penalty is imposed through an official administrative decision.

Under the amended Article 111(6l), the taxpayer must pay the penalty to the bank account of the competent tax office within 14 days of receiving the decision, without waiting for an additional payment request.

This introduces a clear financial consequence for failing to complete an administrative procedure that is already part of fiscal cash register management.

The PLN 300 amount is specifically linked to the late submission of the deregistration application. Other possible compliance issues, such as improper fiscal data handling, must be considered separately under the applicable legislation.

How will these changes affect retailers in practice?

The amendment is particularly relevant for retailers operating multiple stores or regularly replacing fiscal cash registers.

Consider a clothing retailer operating 150 stores across Poland. The company decides to close five locations and replace 20 older fiscal cash registers with newer models.

For each register permanently withdrawn from operation, the retailer must ensure that the required closure procedure is completed, the fiscal data is secured, and the deregistration application is submitted on time.

The company must also maintain the necessary documentation confirming the completion of the procedure.

If the retailer fails to submit an application within the applicable deadline, the tax authority will impose the new PLN 300 penalty.

For large retail chains, managing these obligations across different stores can become challenging, particularly when several devices are replaced or withdrawn simultaneously.

The changes make it more important to maintain accurate records of fiscal cash registers and their operational status.

What does this mean for POS software vendors and fiscal device providers?

The amendment primarily creates a procedural obligation for retailers and taxpayers rather than introducing a new mandatory technical function for fiscal cash registers or POS software.

However, POS software vendors, fiscal device manufacturers, and technology providers can help their customers manage compliance more effectively.

One practical approach is to introduce fiscal register lifecycle management functions that allow businesses to track whether a device is active, withdrawn from use, awaiting deregistration, or officially deregistered.

Systems could also maintain essential information about each fiscal register, including its identification numbers, installation location, withdrawal date, and related deregistration documentation.

Automated notifications and deadline reminders could help retailers avoid missing the required application deadlines.

Another useful improvement would be supporting the secure preservation of fiscal data and relevant documents when a register is permanently removed from operation.

These features are not explicitly required as new software functionalities by the amendment, but they could simplify compliance for retailers operating a large number of fiscal devices.

Implementation Impact and What Businesses Should Do

From January 1, 2027, Polish retailers must pay particular attention to the timely deregistration of fiscal cash registers that are permanently withdrawn from use. Failure to submit the deregistration application within the applicable deadline will result in a PLN 300 financial penalty.

Businesses should review their existing cash register closure procedures, maintain updated records of all fiscal devices, and ensure that responsible employees understand the deregistration requirements.

Retailers should also coordinate with authorized fiscal service providers to complete the required memory readings, reports, and documentation.

For POS vendors and fiscal technology providers, introducing device lifecycle tracking, deadline notifications, and documentation management could help customers meet these obligations.

The priority is to ensure that every fiscal register is properly closed, its data is secured, and the deregistration application is submitted on time.

The source for this text is an article that was published by the Polish Ministry of Finance and the National Revenue Administration - Source Source

Nikolina Basić Senior Legal Consultant Linkedin profile