Cash register in unregistered activity in Poland 2026

Unregistered activity (działalność nierejestrowana) is a form of small-scale enterprise introduced to simplify procedures as much as possible for the smallest economic operators. Despite the many simplifications and exemptions available to people running this type of activity, the question of whether a cash register (kasa fiskalna) is required remains complicated and is often misunderstood. Many people wrongly assume that unregistered activity automatically exempts them from all obligations related to recording sales. Once the activity outgrows the limit and is registered, we can keep its records and settlements as part of our bookkeeping services.

The reality is much more complex, because the rules on cash registers come from the VAT Act, which has its own definitions and rules. This means that even if an activity is not considered a business activity under the Entrepreneurs' Law (ustawa Prawo przedsiębiorców), it may still be subject to VAT obligations. This apparent contradiction is the source of many misunderstandings and mistakes in how entrepreneurs read the rules.

Basic information on unregistered activity in 2026

Unregistered activity is precisely defined in Article 5 section 1 of the Entrepreneurs' Law. Under this provision, as in force from 1 January 2026, an activity carried out by a natural person is not a business activity if the revenue due from it does not exceed a certain financial threshold in any quarter. In 2026 the threshold is PLN 10,813.50 per quarter, which corresponds to 225% of the minimum wage set at PLN 4,806 gross (until the end of 2025 the limit was monthly: 75% of the minimum wage, i.e. PLN 3,499.50). The other conditions and tax consequences of the threshold are summarised in our overview of the 2026 limit for unregistered activity.

Another important condition for an activity to qualify as unregistered is that the person running it must not have carried out a business activity in the last 60 months. This condition is meant to ensure that the exemption is really aimed at people starting a business for the first time or after a long break, and not at those trying to avoid obligations by artificially splitting their business.

The main benefits of unregistered activity include no need to apply for entry in CEIDG (Central Register and Information on Economic Activity), which greatly simplifies getting started. In addition, people running unregistered activity do not have to pay social insurance contributions to ZUS (Social Insurance Institution), which is a significant saving, especially at the beginning.

Unregistered activity also benefits from simplifications in income tax. Revenue from this type of activity is not classified as business income but as revenue from other sources, as provided in Article 20 section 1ba of the PIT Act. As a result, there is no obligation to pay monthly income tax advances or to keep a KPiR. The taxpayer settles unregistered activity once, after the end of the tax year, in the annual PIT-36 return. Upfront payments from customers are a separate matter — we explain when advance payments in unregistered activity become income.

These simplifications make unregistered activity attractive for people testing the market, turning a hobby into a commercial activity or looking for an additional source of income. However, it is important to understand that these simplifications do not apply to all areas of tax law, which is particularly relevant to VAT obligations.

Unregistered activity and the VAT Act

The key to understanding cash registers in unregistered activity is realising that the VAT Act uses its own definitions and contains no special provisions on how sales made in unregistered activity are taxed. This means that all standard VAT rules also apply to this type of activity.

Under Article 15 section 1 of the VAT Act, a taxpayer is an entity that independently carries out business activity, regardless of its purpose or result. Business activity is defined in Article 15 section 2 of the Act and covers any activity of producers, traders or service providers, including entities extracting natural resources and farmers, as well as people practising liberal professions.

It is particularly important that business activity covers in particular activities involving the use of goods or intangible assets on a continuous basis for profit. This definition is much broader than the definition of business activity in the Entrepreneurs' Law and in practice means that a natural person running unregistered activity is, as a rule, a VAT payer if they carry out activities on a continuous basis for profit.

Naturally, in practice, because of the low sales typical of unregistered activity, the person running it can often use the subjective exemption under Article 113 of the VAT Act (limit of PLN 240,000 from 1 January 2026) or other objective exemptions. This does not change the fundamental fact that the relevant provisions of the VAT Act apply to unregistered activity, including those on recording sales with cash registers.

This legal situation means that all rules and principles of the VAT Act also apply to unregistered activity. This concerns both the exemption provisions and the obligations to record sales, issue sales documents and use cash registers. In practice, every case of unregistered activity needs to be analysed individually for VAT obligations.

Cash register obligation in unregistered activity

Because all VAT rules apply to unregistered activity, the provisions requiring sales to natural persons not running a business and to flat-rate farmers (rolnicy ryczałtowi) to be recorded with a cash register also apply. The legal basis for this obligation is Article 111 section 1 of the VAT Act.

This obligation results from the fact that a cash register is used to record sales to final consumers, not from the legal nature of the seller. Therefore, if a person running unregistered activity sells goods or provides services to natural persons not running a business, they should in principle record those sales with a cash register.

To keep cash register records and issue fiscal receipts (paragon) correctly, the taxpayer must have a NIP (tax identification number). As a result, although a person running unregistered activity does not run a business activity within the meaning of the Entrepreneurs' Law, they must use a NIP for tax purposes.

This position was confirmed in the individual tax ruling (KIS) issued by the Director of National Tax Information on 24 September 2018, no. 0111-KDIB3-3.4018.5.2018.2.MS. In that ruling the tax authority stated that a person providing beauty and cosmetology services to natural persons as unregistered activity carries out business activity within the meaning of Article 15 section 2 of the VAT Act. As a result, that person is a taxpayer under the Act and must apply for a NIP.

The application for a NIP is filed on form NIP-7, ticking the box (in the version of the form discussed in that ruling – part A.4 point 2) for a person subject to VAT registration or already registered as a VAT payer. This requires the taxpayer to act consciously and understand their VAT status.

Exemptions from the cash register obligation

Despite the general cash register obligation for people running unregistered activity, there are situations in which the taxpayer may be exempt. These exemptions result from the Minister of Finance regulation of 17 December 2024 on exemptions from the obligation to record sales with cash registers (Dz.U. (Journal of Laws) 2024 item 1902, in force until 31 December 2027), which also applies accordingly to unregistered activity.

The regulation provides for various categories of exemptions, which may depend on the type of activity, turnover or specific circumstances. The most commonly used exemption is based on turnover: sales to natural persons not running a business and to flat-rate farmers of up to PLN 20,000 a year (for those starting out – in proportion to the period of activity). In certain cases, a person running unregistered activity may meet the conditions set out in the regulation and be exempt from using a cash register.

Remember, however, that certain categories of supplies of goods and services do not benefit from the cash register exemption, regardless of other circumstances. This applies in particular to some personal services, such as hairdressing, beauty or cosmetology services.

The practical application of these rules can be illustrated with an example: a natural person decides to provide hairdressing services as unregistered activity. Because of low annual sales, they use the subjective VAT exemption under Article 113 of the Act. Even so, the cash register exemption does not apply to hairdressing services. As a result, although the unregistered activity is VAT-exempt, the taxpayer must still have a cash register and issue fiscal receipts when selling to natural persons not running a business.

This situation shows that the cash register obligation and the VAT exemption are two independent issues that can occur in different combinations. A taxpayer may be VAT-exempt but still required to record sales on a cash register, or conversely – may be a VAT payer but exempt from having a cash register. Separate rules also decide whether the sale of fixed assets has to be recorded on the till.

When you are exempt from both NIP and the cash register

There are, however, situations in which a person running unregistered activity may be fully exempt both from the cash register obligation and from applying for a NIP. This happens when the taxpayer is entitled to the VAT exemption and, at the same time, the activities carried out are exempt from recording sales on a cash register.

The conditions for these exemptions are strictly defined in the relevant provisions and require all criteria to be met at the same time. Meeting only one condition is not enough – the conditions for the VAT exemption and for the cash register exemption must both be met.

A practical example of such a situation is the individual tax ruling issued by the Director of National Tax Information on 29 June 2023, no. 0112-KDIL3.4012.226.2023.2.AK. In that ruling the tax authority accepted as correct the position that a person providing educational services, specifically private tutoring as unregistered activity, does not have to file the NIP-7 identification application.

In this particular case, the applicant used the subjective VAT exemption because she did not exceed the then applicable annual turnover limit of PLN 200,000 under Article 113 section 1 of the VAT Act (from 1 January 2026 the limit is PLN 240,000). In addition, she did not provide the services listed in Article 113 section 13 of the Act, which are excluded from the subjective exemption. She also had no obligation to use a cash register because of her turnover, and did not carry out the activities listed in the regulation on exemptions from recording sales with cash registers.

As a result, the tax authority stated that in such a situation there is no obligation to apply for a NIP via the NIP-7 identification application. This ruling shows that in specific, strictly defined cases unregistered activity can indeed benefit from full exemptions from both VAT obligations and the cash register obligation.

How to obtain a NIP for unregistered activity

Where a person running unregistered activity must have a cash register, they first need to obtain a NIP. This requires filing the relevant application and completing certain formalities necessary to operate correctly in the tax system.

The basic document in this procedure is the application for a NIP filed on form NIP-7. In this application it is particularly important to tick the box for a person subject to VAT registration or already registered as a VAT payer.

Filing the application also requires preparing the relevant documents and indicating the nature of the activity. It is important to describe precisely the type of activity to be carried out and to indicate the circumstances that make a NIP necessary in view of VAT obligations.

1. Prepare the NIP-7 application, ticking the box for a person subject to VAT registration
2. Describe the nature of the unregistered activity in the application
3. State the reasons why a NIP is needed in view of VAT obligations
4. File the application with the tax office (urząd skarbowy) competent for your place of residence
5. Wait for the NIP to be assigned and receive confirmation of it
6. Register the cash register using the NIP you received
7. Start recording sales in line with the applicable rules

Once you have a NIP, you can register the cash register and start recording sales correctly in line with the rules. It is important to complete the whole process before starting any activity that requires a cash register, because selling without the required records may result in financial penalties.

Types of activity that need special attention

Some types of activity carried out as unregistered activity need special attention as regards the cash register obligation. This applies above all to services provided directly to final consumers, where the risk of needing a cash register is highest.

Hairdressing, beauty and cosmetology services are an example of an activity that practically always requires a cash register when selling to private individuals, regardless of turnover. These services are expressly excluded from the exemptions from recording sales on a cash register (§ 4 section 1 point 2 letter j of the regulation).

The situation is similar for catering services provided in permanent premises (also seasonally) and catering for external customers, vehicle repairs and tyre changes, and certain other services listed in § 4 of the regulation. In these cases, even a small scale of activity does not exempt you from having a cash register if you sell to natural persons not running a business.

• Hairdressing and beauty services require a cash register regardless of turnover
• Catering in permanent premises and catering for consumers must be recorded on a cash register
• Vehicle repairs, tyre changes and roadworthiness tests for natural persons require a cash register
• Retail sales of goods to final consumers must be recorded on a cash register after exceeding PLN 20,000 of turnover, and certain goods (e.g. electronics, alcohol, perfumes) – always
• Educational services may benefit from exemptions if certain conditions are met

On the other hand, some types of activity may benefit from broader exemptions. This applies in particular to educational services, as shown by the ruling on private tutoring, where it was possible to be exempt both from VAT and from the cash register obligation.

Consequences of not meeting the obligations

Failing to meet the obligations related to recording sales on a cash register in unregistered activity can have serious financial and legal consequences. The KAS (National Revenue Administration) authorities treat these breaches just as seriously as in the case of a registered business.

The basic sanctions concern selling without the required cash register records or not issuing receipts. Such an act is punishable by a fine under Article 62 § 4 of the Fiscal Penal Code (in a less serious case – a fine for a fiscal petty offence, Article 62 § 5). For taxpayers who are not liable for this act under the Fiscal Penal Code, the head of the tax office sets an additional tax liability of 30% of the input VAT on purchases of goods and services (Article 111 section 2 of the VAT Act).

In addition, if irregularities in the tax settlements are found, the tax authorities may determine tax arrears together with late-payment interest. In more serious cases, proceedings for a fiscal petty offence or a fiscal offence may also be initiated.

A person running unregistered activity providing beauty services did not use a cash register for a year, wrongly assuming that unregistered activity exempts them from this obligation. As a result of a tax audit, they face liability under Article 62 § 4 of the Fiscal Penal Code (a fine) and must start recording sales on a cash register without delay. Not having a cash register does not take away their subjective VAT exemption – the cash register and the VAT exemption are separate issues.

It is also important that not having a NIP when one is required may further complicate the taxpayer's legal situation. The tax authorities may see this as an attempt to conceal the true nature of the activity, which may lead to further legal consequences.

In practice, this means that anyone considering unregistered activity should carefully analyse their obligations as regards recording sales and, in case of doubt, consult a tax adviser or apply for an individual tax ruling from the tax authority.

Practical tips for people running unregistered activity

Running unregistered activity in line with the rules requires a thoughtful approach and an understanding of all the obligations arising from various legal acts. The first step should be a careful analysis of the planned activity and determining whether it will require a cash register.

Identifying your customers is crucial. If the activity is aimed mainly at natural persons not running a business, the likelihood of needing a cash register is high. Activity aimed exclusively at businesses, on the other hand, is not subject to the cash register obligation (Article 111 section 1 of the VAT Act concerns sales to natural persons not running a business and to flat-rate farmers), and sales are documented with invoices.

It is equally important to understand the difference between the VAT exemption and the exemption from the cash register obligation. These two exemptions are independent and can occur in different combinations, so each case needs to be analysed individually.

If you are unsure how to interpret the rules, it is advisable to apply for an individual tax ruling from the Director of National Tax Information. Although this takes time and involves a fee (PLN 40 for each set of facts), it gives legal protection if the actual facts match those described in the application.

It is also worth following changes in the law, because the rules on unregistered activity and cash registers are amended from time to time. Pay particular attention to changes in implementing regulations, which may affect the scope of exemptions from the cash register obligation.

Frequently asked questions