Having to use a cash register (kasa fiskalna) comes with a number of additional obligations that taxpayers recording sales must meet. One of the most important requirements is to have cash registers regularly inspected by an authorised service provider. The VAT Act and the regulation on cash registers set out in detail how this process should be carried out and what the consequences are of failing to meet the obligations related to servicing fiscal devices. Businesses with several devices also need to report sales from several cash registers correctly in JPK.
Understanding the difference between servicing and a technical inspection of a cash register is crucial for business owners, as it directly affects how they organise their records and comply with tax rules. Getting these obligations wrong can lead not only to problems with the tax authorities but also to disruption of the business.
Legal basis for the obligation to service cash registers
The legal basis for the obligation to carry out technical inspections of cash registers is Article 111(3a)(4) of the VAT Act, which clearly sets out the obligations of taxpayers who have cash registers. Under this provision, all business owners required to have a cash register must have their devices regularly inspected by the relevant cash register service provider.
The obligation to have a cash register technically inspected follows directly from the VAT Act and applies to all taxpayers who have cash registers. If the cash register is not inspected on time, the head of the tax office (urząd skarbowy) imposes a financial penalty of PLN 300 on the taxpayer (Article 111(6ka) of the VAT Act), and a taxpayer who used the relief for buying the cash register must repay it if they fail to have it inspected on time within 3 years of starting to record sales (Article 111(6))
This obligation is specified in detail in the regulation on cash registers (since 1 July 2025, the Regulation of the Minister of Finance of 25 June 2025, Journal of Laws (Dz.U.) 2025, item 845), which in § 9(1) sets out the specific actions that taxpayers using cash registers must take. This regulation is a practical tool for implementing the statutory provisions and contains detailed procedures and deadlines that business owners must comply with.
It is worth stressing that this obligation is not just a formal administrative requirement – it ensures that the sales recording system works properly and protects the state's fiscal interests. Regular technical inspections make it possible to detect any irregularities in how cash registers work and to ensure that they comply with the applicable technical and legal standards. We enter cash register reports in the VAT records and JPK files for clients of our accounting services.
The taxpayer's detailed obligations regarding cash registers
The regulation on cash registers imposes a number of detailed obligations on taxpayers using cash registers that go beyond the technical inspection itself. Under § 9(1) of the regulation, taxpayers must systematically perform the following tasks related to the proper functioning of their fiscal devices.
The first and basic obligation is to check that the cash register is working correctly, with particular attention to the key elements of how it works. This includes checking that the names of goods and services are programmed correctly, verifying the tax rates, checking the recording currency together with its symbol and the conversion rate, checking the date and time display and making sure that names of goods and services are correctly assigned to the relevant tax rates or to the exemption.
A taxpayer using a cash register must regularly check that it is programmed correctly, especially as regards the names of goods and services and the tax rates assigned to them. Any irregularity in this area can lead to errors in sales records and problems with settling VAT
Another important obligation is to report every irregularity in how the cash register works to the service provider without delay. This requirement is crucial for keeping records continuous and correct, as it allows a quick response to any failures or errors in how the device works. The taxpayer must not ignore irregularities they have noticed or put off reporting them.
The third obligation is to make cash registers available for inspection of their integrity and correct operation whenever the competent authorities request it. This means that the business owner must be ready for inspections by the tax offices and provide full access to their fiscal device and the related documentation.
- Checking that the names of goods and services are programmed correctly
- Verifying the tax rates and how they are assigned
- Checking the recording currency and its technical parameters
- Checking that the date and time are displayed correctly in the system
- Verifying that products are correctly assigned to tax rates
The last but equally important obligation is to have cash registers undergo the mandatory technical inspection carried out by the main service provider or a service provider, within the deadlines set by the regulation.
Deadlines and scope of the mandatory technical inspection
The regulation on cash registers sets precise deadlines for mandatory technical inspections of cash registers. Under § 55 of the regulation, the mandatory technical inspection of a cash register must be carried out at least every 2 years. This is the maximum period that may pass between inspections, but nothing prevents you from having them carried out more often.
The first mandatory technical inspection of a cash register must be carried out within 2 years of the date of fiscalisation of the device. This period is counted precisely from the moment the cash register is put into fiscal use, not from the date it was bought or installed
It is particularly important to determine when the period for the first inspection starts. The period for the first mandatory technical inspection is counted from the date of fiscalisation, which means it is counted not from the purchase or installation of the cash register but from the day it was actually put into use for fiscal recording.
The scope of the mandatory technical inspection is very broad and covers all key aspects of how the cash register works. During the inspection, the service technician must check the following elements in detail:
| Element of the inspection | Details of the check | Purpose of the check | Consequences of irregularities |
|---|---|---|---|
| Condition of the seals | Number and integrity of the seals | Ensuring integrity | Suspicion of tampering |
| Device housing | External technical condition | Protection of internal mechanisms | Risk of damage |
| Legibility of documents | Print quality of receipts | Correct sales records | Breach of the obligation to print legibly |
| Operating program | Compliance with the documentation | Proper functioning of the system | Errors in records |
The first area checked is the condition and number of the cash register's seals and whether they match the entries in the cash register logbook and the documentation related to the servicing carried out. Seals protect the cash register against unauthorised access to its internal mechanisms and are a key element of protecting the device's integrity.
Another element is checking the condition of the cash register housing, which aims to detect any mechanical damage that could affect the proper functioning of the device. A damaged housing may indicate improper use of the cash register or attempts to tamper with its mechanisms.
During the technical inspection, the service technician checks the legibility of the documents printed by the cash register. The taxpayer must keep the cash register in a technical condition that allows the fiscal receipt or invoice to be printed legibly (§ 6(1)(9) of the regulation), and illegible documents may be challenged during an inspection and cause problems with sales records
A very important element of the inspection is checking the legibility of the documents printed by the cash register (§ 57(1)(3) of the regulation). Illegible fiscal receipts (paragon) breach the obligation to print legibly and may be challenged during an inspection, which can lead to problems with keeping sales records correctly and settling taxes. How many years printed receipts and their copies must be kept is explained in our guide on keeping receipts.
The service technician also checks the cash register's operating program and memory reading program, and for cash registers with an electronic copy record, the archiving program. All these elements must match the entries in the cash register logbook and the servicing documentation, which ensures the integrity of the recording system.
- Checking that the cash register correctly issues fiscal documents
- Checking that the customer display works
- Assessing the technical condition of the internal power batteries or accumulators
- Verifying that the cash register clock is set correctly
The difference between servicing and a technical inspection of a cash register
In business practice, the terms servicing and technical inspection of a cash register are often used interchangeably, which can lead to misunderstandings and a misreading of business owners' obligations. The law, however, clearly distinguishes between these two concepts and defines their scope and relationship.
According to the definition in § 2(33) of the regulation on cash registers, servicing is a much broader concept than a technical inspection. Servicing means activities covering fiscalisation, repairs, maintenance and technical inspections of cash registers. This means that a technical inspection is just one component of the broader concept of servicing.
Cash register servicing covers all activities aimed at keeping the device in a technical condition that allows sales to be recorded correctly. A technical inspection is only one of these activities, alongside fiscalisation, repairs and routine maintenance of the device
Fiscalisation of a cash register is the process of putting it into operation for the first time and configuring it for fiscal recording, which is carried out once after the device is bought. Repairs are interventions aimed at restoring the proper functioning of the cash register after a failure or damage. Maintenance covers routine upkeep that aims to prevent failures and ensure that the device works properly for a long time.
A technical inspection is a periodic, comprehensive check of the technical and functional condition of the cash register, carried out in line with set deadlines and procedures. It is a planned activity whose purpose is to detect any irregularities and to confirm that the device complies with the technical and legal requirements.
A business owner running a grocery shop had to call a service technician twice in one year. The first time it was to repair a damaged receipt printer (repair servicing), and the second time it was a planned technical inspection carried out in line with the requirements of the regulation. Both activities were part of the broader concept of cash register servicing.
This difference matters in practice for business owners, as it affects how they plan the costs of maintaining cash registers and organise their recording processes. A technical inspection can be planned in advance, while other servicing may be needed urgently, which requires appropriate organisational and financial preparation.
How cash register servicing is organised
Cash register servicing in Poland is organised hierarchically, which ensures quality control of services and compliance with the legal requirements. The system is based on a division into main service providers and service providers, which operate within a defined legal and organisational framework.
Under § 9(2) of the regulation on cash registers, a taxpayer using a cash register may use only the services of a main service provider or a service provider. This requirement aims to ensure an appropriate level of competence and responsibility of the entities providing servicing.
A taxpayer may change the service provider for their cash register but must notify the main service provider of this change within 5 days of making it. The consent of the main service provider is not required for the change
An important right of the taxpayer is the option to change the service provider. The business owner may make such a change without obtaining the consent of the main service provider but must notify it within 5 days of making the change (§ 9(3)–(4) of the regulation). The condition for the change is choosing a provider that is included in the official list of service technicians on the day of the change.
Servicing at national level is the responsibility of the main service provider, which organises and provides servicing throughout Poland. The manufacturer of the cash register must provide the minister responsible for public finance with information on the organisational structure of the cash register service and its distribution across the country within 14 days of receiving the confirmation that the given type of cash register meets the required functions and technical requirements.
The servicing documentation system is also strictly regulated. The main service provider keeps the servicing documentation, and service providers hand over this documentation or a copy of it for quarterly periods, by the 10th of the month following the end of the quarter. This documentation must be kept for 5 years from the end of the calendar year in which it was received.
- Choosing a service provider from the official list
- Concluding a contract for servicing
- Notifying the change of service technician if it is changed
- Meeting the deadlines for technical inspections
- Cooperating with the service technician during the work
Rights and obligations of service technicians
Cash register servicing may be entrusted only to authorised service technicians who meet certain qualification requirements and hold the relevant authorisations. Under § 43 of the regulation on cash registers, servicing is carried out by service technicians authorised by the main service provider.
The service technician's authorisation is confirmed by a service technician ID issued by the main service provider according to the template in Annex 7 to the regulation. This document has limited validity – the service technician ID is valid for one year from the date of issue and authorises the technician to service the types of cash registers specified in it.
Before servicing any cash register, the service technician must show a valid service technician ID. This document confirms their authorisation to work on specific types of cash registers and is valid for one year from the date of issue
The quality control system for service technicians allows the main service provider to withdraw the authorisation. This may happen if the technician breaches the conditions for servicing or, while performing their duties, enables the taxpayer to keep unreliable records. The service provider must inform the main service provider without delay of every breach by a service technician.
The service technician's documentation obligations include entering their identification details in the cash register logbook and making chronological entries about the work carried out. The content of these entries must also be included in the servicing documentation. All entries in the cash register logbook must be legible, and entries about servicing carried out must also be signed by the technician with their full name and include their ID number.
The deadlines for servicing are strictly defined. Servicing must begin no later than 48 hours after the taxpayer's request, unless otherwise agreed. For the mandatory technical inspection, the deadline is set differently – the service technician must carry out the inspection within 3 days of the taxpayer's request.
- Holding a valid service technician ID for the specific types of cash registers
- Making legible entries in the cash register logbook with a signature and ID number
- Meeting the deadlines for starting servicing (48 hours, technical inspection – 3 days)
- Cooperating with the tax authorities at their request
- Keeping servicing documentation in line with the requirements
An important restriction is the ban on servicing cash registers by the taxpayer or persons employed by them. Under § 53 of the regulation, cash registers used for recording sales may not be serviced by the taxpayer or by a person employed by them under an employment contract, a contract of mandate (umowa zlecenia), a contract for specific work (umowa o dzieło), an agency contract or any other contract of a similar nature.
List and search engine of service technicians
The register of service technicians authorised to service cash registers is kept centrally by the KAS (National Revenue Administration). Under § 50 of the regulation on cash registers, the main service provider has a number of obligations related to keeping documentation on service technicians.
The basic obligation is to draw up and keep a list of service technicians authorised to service cash registers of a given type or types. This list must be up to date and contain all relevant information about the authorised service technicians. The main service provider must send the list of service technicians and any changes to the data in it by electronic means within 3 days of drawing it up or of the changes occurring to the Head of the National Revenue Administration.
The Head of the National Revenue Administration keeps a central electronic list of service technicians, made up of data sent by the main service providers. This list is made available in the Public Information Bulletin of the Ministry of Finance (§ 51(2) of the regulation) and allows taxpayers to verify service technicians' authorisations
On the basis of the data received, the Head of the National Revenue Administration keeps an electronic list of service technicians authorised to service cash registers of a given type or types. This list is a central database fed with information sent on the basis of the lists of service technicians and changes to the data in them.
The list of service technicians contains the following key information:
| Type of information | Description of the data | Practical importance | Use |
|---|---|---|---|
| ID number | Unique service technician number | Identification of the authorised technician | Verification during servicing |
| NIP of the main service provider | Identifier of the main provider | Determining responsibility | Contact in disputes |
| NIP of the service provider | Identifier of the contractor | Identification of the direct contractor | Choosing a technician |
| Expiry date | Period of validity of the authorisation | Checking that authorisations are current | Planning servicing |
The detailed data in the list include the service technician ID number, the NIP (tax identification number) of the main service provider that authorised the technician, the NIP of the service provider, the expiry date of the technician's authorisation and the type(s) of cash registers the technician is authorised to service.
To make this information easier to access, a search engine of service technicians has been created, available at: https://www.podatki.gov.pl/wyszukiwarka-uprawnien-serwisantow/. This tool allows taxpayers to quickly verify the authorisations of potential service technicians and check whether a given technician is authorised to service a specific type of cash register.
A business owner running a restaurant needed their cash register serviced. Before choosing a service technician, they used the official search engine on podatki.gov.pl and checked, by ID number, the authorisations of the technicians of several service companies in their area. This allowed them to choose a technician with a current authorisation to service their type of cash register.
The list is updated in a way that keeps the information current. The Head of the National Revenue Administration must update the list of service technicians with the data sent by the main service provider without delay, but no later than the next working day after the data is delivered by that provider.
Practical aspects of organising a technical inspection
Organising a technical inspection of a cash register requires proper preparation by the business owner and cooperation with an authorised service technician. This process should be treated as a routine business activity that is necessary to stay compliant with the rules and to keep the sales recording system working properly.
The first step in organising a technical inspection is planning well in advance. Since inspections must be carried out at least every 2 years, the business owner should keep a calendar of deadlines for all their cash registers. It is worth planning the inspection several months in advance to avoid a situation where the inspection deadline passes and no service technician is available in time.
A business owner should keep a calendar of technical inspection deadlines for all their cash registers and plan them well in advance. Missing the inspection deadline may result in a financial penalty of PLN 300 (Article 111(6ka) of the VAT Act) and disruption to the business
Choosing the right service technician is another key element of the process. The business owner should use the official search engine of service technicians on podatki.gov.pl to make sure that the chosen technician has current authorisations to service their type of cash register. It is also worth checking the technician's references and experience, especially for cash registers with special technical requirements.
Preparing the cash register for the technical inspection involves a few practical steps. The business owner should make sure that the cash register logbook is up to date and contains all the required entries, that the cash register is available at the agreed time and that no busy sales periods are planned that could be disrupted by the device being temporarily unavailable. Before the technician's visit, it is also worth bringing the log of obvious errors up to date.
- Checking the date of the last technical inspection in the cash register logbook
- Planning the inspection well before the deadline
- Choosing an authorised service technician from the official list
- Agreeing on the inspection date with business needs in mind
- Preparing the cash register documentation for the technician's check
During the technical inspection, the business owner should cooperate with the service technician and provide all the necessary information and documentation. The service technician is entitled to full access to the cash register and the related documents so that they can carry out a comprehensive check in line with the requirements of the regulation.
After the technical inspection, the service technician makes the relevant entries in the cash register logbook and issues documentation confirming that the inspection was carried out. For online cash registers, the inspection is also recorded in the fiscal memory (§ 57(2) of the regulation), and fulfilment of the obligation is established on the basis of the entry of the result in the cash register logbook and the record of the inspection date in the Central Cash Register Repository (Article 111(3aa) of the VAT Act). The business owner should check that these entries are correct and keep copies of the servicing documents for their own records.
The costs of the technical inspection are borne by the business owner and, as a rule, are tax-deductible costs. It is worth including these costs in budget planning and considering a service contract, which may offer preferential terms for regular technical inspections.
