The summer holiday period is a time of intense trading in tourist resorts. Ice cream kiosks, cafés, food outlets and souvenir stalls are an inseparable part of the holiday landscape. However, business owners running such seasonal activities are often unaware of all their obligations related to recording sales. Using cash registers (kasa fiskalna) during the holiday season raises many questions, especially given the variety of ways of doing business – from stationary restaurants to mobile sales points on beaches.
The rules on cash registers make no exceptions for seasonal activities. This means that sellers trading during the holiday season are subject to the same sales recording rules as businesses operating all year round. At the same time, there are certain exemptions and reliefs that can make running a seasonal business much easier. The key is to understand when the obligation to use a cash register is absolute and when you can use an exemption.
Basic rules for recording sales during the holiday season
Under the rules in force, every business owner selling to private individuals who do not run a business or to flat-rate farmers must, as a rule, record sales on a cash register (Article 111(1) of the VAT Act), unless they use an exemption. This rule covers all forms of trade, regardless of where and how the business is carried on. It applies both to stationary sales points and to mobile trade on beaches, promenades or in other tourist locations. The season also means letting rooms and flats – the rules are explained in short-term holiday rental and the cash register.
The obligation to record sales on a cash register covers all forms of holiday trade, including stands, stalls, seasonal kiosks and mobile trade. As a rule, every amount of revenue from sales to private individuals must be recorded on a cash register
The type of activity is particularly important. Mobile trade, so popular during the holiday season, is subject to the same rules as stationary sales. This means that sellers offering their products directly on beaches, near hotels or in other places where tourists gather must be ready to record every transaction properly.
It is worth stressing that the rules do not distinguish between business owners based on how long they operate during the year. A business owner operating only in the summer season has the same obligations as one operating all year round. The only difference may be the available exemptions, which are often more favourable for activities with lower turnover, typical of seasonal trade.
Exemptions from the obligation to use a cash register
A significant relief for business owners selling during the holiday season is the possibility of using an exemption from the obligation to use a cash register. This exemption is particularly important for seasonal activities, which often have lower annual turnover.
The cash register exemption is available to business owners whose sales to private individuals in the previous tax year did not exceed PLN 20,000. This exemption applies until 31 December 2027 at the latest (§ 3(1) of the Regulation of the Minister of Finance of 17 December 2024, Journal of Laws (Dz.U.) 2024, item 1902)
The conditions for the exemption are set out precisely in the rules. The first group consists of taxpayers whose sales (excluding VAT) to private individuals who do not run a business and to flat-rate farmers did not exceed PLN 20,000 in the previous tax year. For taxpayers who started their activity in the previous year, the value of sales is calculated proportionally for the whole year.
The second group covers taxpayers starting their activity after 31 December 2024. For them, the criterion is the expected value of sales, which, in proportion to the period of activity in the given tax year, must not exceed PLN 20,000. This solution is particularly favourable for new business owners planning a seasonal activity.
It is also important that exceeding the exemption limit does not mean an immediate obligation to use a cash register. The taxpayer must start recording sales on a cash register only after two months following the month in which the sales limit was exceeded (§ 5(1) of the regulation). This gives business owners time to prepare for their new obligations. Holiday promotions follow their own rules too, for example selling services with a free gift on a cash register.
Specific types of activity exempt from the cash register
In addition to exemptions based on the value of sales, there are also exemptions for certain types of activity. These exemptions are particularly important for tourism and holiday activities, as they cover services often provided in the summer.
The cash register exemption covers accommodation services provided by children's camps and other services of tourist accommodation facilities – in both cases only when provided by children's camps (items 22 and 23 of the annex to the regulation). It also applies to short-stay accommodation services not elsewhere classified, if they have been fully documented by an invoice (item 24)
Accommodation services provided by various hotel facilities are a special category. The exemption applies only to services provided by children's camps, which is important for organisers of summer camps for children. Similarly, other services of tourist accommodation facilities and short-stay accommodation without service are exempt, but again only in the case of children's camps.
It is worth noting the accommodation services that may be exempt from the obligation to use a cash register. This applies to short-stay accommodation services not elsewhere classified, excluding hotel and tourist services, but only if these services have been fully documented by an invoice.
These exemptions are of real practical importance, as many tourist facilities provide mixed services, combining accommodation with food service or retail. In such cases, the types of activity must be clearly separated and the appropriate recording rules applied to each of them.
Absolute obligation to use a cash register in food service
One of the most important rules that business owners running holiday activities must know is the absolute obligation for businesses in the food service sector to use a cash register. This obligation does not depend on turnover, and no value-based exemptions can be used to avoid it.
Business owners providing food services through stationary food service outlets, including seasonal ones, and catering services have an absolute obligation to use online cash registers. This obligation does not depend on turnover
The rules clearly state that businesses providing food services cannot use the cash register exemption under any circumstances (§ 4(1)(2)(i) of the regulation; the only exceptions are meals on board aircraft and canteens of educational establishments, such as schools, nurseries and universities, made available only to their pupils or students and staff – items 45 and 47 of the annex, § 4(3)(2)(d)). This applies to services provided by stationary food service outlets, including those operating seasonally, and to food preparation services for external customers, i.e. catering.
It is important to distinguish between stationary food service outlets and mobile sales points. According to the definition used by Statistics Poland (GUS), a food service outlet is a permanent or seasonal food service establishment or point whose business is preparing and selling meals and drinks for consumption on the premises and to take away. The key point is that mobile retail sales points and vending machines are not classed as food service outlets.
In addition, since 1 January 2021, business owners selling in the food service sector have been required to use online cash registers. This means they can no longer use older cash register models with an electronic or paper copy record. This change is particularly important for seasonal outlets, which have to invest in modern fiscal devices.
Definition and types of food service outlets
Understanding the definition of a food service outlet is crucial for applying the cash register rules correctly. As there is no precise definition in the VAT Act or in the exemptions regulation, practice relies on interpretations by the tax authorities and on statistical definitions.
According to the definition used by Statistics Poland (GUS), a food service outlet is a permanent or seasonal food service establishment or point whose business is preparing and selling meals and drinks for consumption on the premises and to take away. This definition covers a wide range of activities, from restaurants and bars to small food service points.
A seasonal food service outlet is an outlet that operates periodically and for no more than 6 months in a calendar year. Stationary food service outlets include bars, food service points, restaurants, canteens and seasonal food service outlets
The tax authorities distinguish two main types of food service outlets:
- Outlets open to the public, serving all customers
- Outlets serving a specific group of consumers (staff canteens, hotel restaurants)
For holiday activities, the distinction between permanent and seasonal outlets is particularly important. A permanent food service outlet is one that is open throughout the calendar year, possibly with breaks for reasons such as renovation, temporary lack of staff or stocktaking. A seasonal food service outlet operates periodically and for no more than 6 months in a calendar year.
Food service outlets can operate in various locations, which is particularly important for the tourism sector. They can operate in hotels, motels, inns, hostels, campsites, guesthouses, holiday homes and other short-stay accommodation. They can also operate in railway carriages that form part of a train and on passenger ships.
Food service points and their specific features
Food service points are a special category of food service outlets that is very important for holiday trade. They are outlets with limited food service activity, which is often typical of small seasonal businesses in tourist resorts.
Food service points include, among others:
- Fish fry shops
- Drinks bars
- Ice cream parlours
- Snack bars in cinemas, stadiums and other entertainment venues
This category covers many types of business popular during the holiday season, such as ice cream parlours on promenades, drinks points on beaches or small bars offering simple meals.
A food service point is a food service outlet with limited food service activity, such as a fish fry shop, drinks bar, ice cream parlour or snack bar. These points must use online cash registers regardless of turnover
It is important that food service points, despite their limited nature, are subject to the same cash register rules as full restaurants. This means that the owner of a small seasonal ice cream parlour has the same obligation to use an online cash register as the owner of a large restaurant.
It is worth stressing the difference between food service points and mobile sales points. Mobile retail sales points and vending machines are not classed as food service outlets, which means they can use the value-based exemptions from the cash register obligation. This difference is crucial for business owners engaged in mobile trade in food products.
Practical aspects of running a seasonal ice cream parlour
Ice cream parlours are one of the most popular types of seasonal business in tourist resorts. Their specific nature requires particular attention to fiscal obligations, as they often combine selling products with food services.
The way the ice cream parlour operates is crucial, and above all whether it operates in a fixed location. A stationary ice cream parlour – including a seasonal one – is a food service outlet regardless of whether customers eat their desserts at tables or take them away: the Polish Classification of Activities classes ice cream parlours as permanent food service outlets (PKD 56.10.A). In such a case, the owner has an absolute obligation to use an online cash register, regardless of turnover.
A stationary ice cream parlour – including a seasonal one and one selling only for takeaway – is treated as a food service outlet. The owner of such an ice cream parlour must use an online cash register regardless of sales value
The situation is different for mobile ice cream sales, e.g. from a cart or a food trailer without a fixed point of sale (PKD 56.10.B – mobile food service outlets). Such an activity is not carried on by a stationary food service outlet, which means it can use the value-based exemptions from the cash register obligation (individual tax ruling (KIS) of the Director of the National Tax Information of 29 April 2026, 0114-KDIP1-3.4012.201.2026.2.PRM).
Owners of seasonal ice cream parlours can use the relief for buying an online cash register if they meet the conditions of Article 111(4) of the VAT Act. The relief is 90% of the net price of the cash register, but no more than PLN 700. This significant support can substantially reduce the costs of starting a seasonal business or adapting to the new rules.
Procedures when the exemption limit is exceeded
Business owners using the cash register exemption must monitor their sales on an ongoing basis so as not to exceed the exemption limit. Exceeding this limit triggers certain procedures that are important for the further running of the business.
When the value of sales exceeds PLN 20,000, the business owner does not have to start using a cash register immediately. The rules provide for a transition period of two months from the end of the month in which the limit was exceeded. This period is meant to allow the business owner to prepare for the new obligations.
- Monitoring the value of sales on an ongoing basis
- Identifying the moment the PLN 20,000 limit is exceeded
- Calculating the date from which the cash register obligation applies
- Choosing and buying a suitable online cash register
- Registering the cash register with the tax office (urząd skarbowy)
- Starting to record sales in line with the rules
The transition period is of key practical importance, especially for seasonal businesses. It allows the business owner to prepare calmly for the new obligations, choose a suitable fiscal device and complete the necessary formalities. At the same time, the business owner must remember to start using the cash register on time, as missing the deadline may lead to sanctions.
Reliefs and support for business owners
The law provides various forms of support for business owners required to use cash registers. The most important is the relief for buying an online cash register, which can significantly reduce the costs of complying with the rules.
| Type of business owner | Amount of relief | Maximum amount | How it is settled |
|---|---|---|---|
| Active VAT payer | 90% of the net price | PLN 700 | Through JPK_V7 |
| VAT-exempt | 90% of the net price | PLN 700 | Refund application |
| New business owner | 90% of the net price | PLN 700 | Depending on VAT status |
The relief for buying an online cash register is 90% of the net price of the cash register, but no more than PLN 700. Both active VAT payers and VAT-exempt business owners can use the relief. The relief is available for each cash register to taxpayers who started recording sales on time or – where the obligation did not arise – started doing so voluntarily and had not used cash registers before; the cash register must be bought no later than 6 months after recording started. The relief must be repaid, among other things, if within 3 years of starting to record sales the taxpayer closes the business or fails to have the cash register technically inspected on time (Article 111(4) and (6) of the VAT Act). The way the relief is settled depends on the business owner's tax status. Practical questions about recording sales, such as when to issue a receipt for a payment after hours, are dealt with separately.
The relief for buying an online cash register is 90% of the net price of the cash register, but no more than PLN 700. Both active VAT payers and VAT-exempt business owners can use the relief
Active VAT payers settle the relief through JPK_V7 (VAT return with records, SAF-T file). They report the amount of the relief in the relevant field of the file for the period in which they started recording sales on the cash register, or for later periods. If the relief exceeds the output VAT for the period, the surplus can be claimed as a refund to a bank account or carried forward to the following settlement periods (§ 3 of the Regulation of the Minister of Finance of 29 April 2019, Dz.U. 2019, item 820). We report the cash register relief in JPK_V7 for the clients whose books we keep – see our accounting services.
VAT-exempt business owners must submit an application to the head of the tax office for a refund of the amount spent on buying the cash register – in the month following the month in which they started recording sales (§ 4(1) of that regulation); the tax office refunds it within 25 days of the application (Article 111(5) of the VAT Act). This ensures that all business owners are treated equally, regardless of their VAT status.
Inspections and enforcement
Compliance with the cash register rules is checked by the tax authorities. Inspections can take the form of visits to the business premises as well as an analysis of the business owner's accounting and tax records.
Inspectors pay particular attention to whether all sales transactions are recorded correctly. Every sale to a private individual should be recorded on the cash register, and the customer should receive a fiscal receipt (paragon). Selling without using the cash register or failing to issue a receipt is punishable by a fine of up to 180 daily rates, and in minor cases by a fine for a fiscal petty offence (Article 62 § 4 and § 5 of the Fiscal Penal Code), often imposed by a penalty notice (mandat) – up to five times the minimum wage, i.e. up to PLN 24,030 in 2026 and up to PLN 24,750 from 1 January 2027 (Article 48 § 2 KKS).
The tax authorities check whether sales are recorded correctly on cash registers. If the taxpayer does not use an exemption, every sale to a private individual must be recorded on the cash register, and the customer should receive a fiscal receipt
For seasonal businesses, inspections can take place at different times of the year. The tax authorities can check both whether sales were recorded correctly during the season and whether annual tax settlements match the business owner's actual activity.
Business owners running seasonal activities should take particular care with their records. All documents related to the business, including fiscal receipts, purchase invoices for goods and other accounting documents, should be kept for the period required by law – as a rule until the tax liability becomes time-barred, i.e. 5 years from the end of the year in which the tax payment deadline passed (Article 112 of the VAT Act, Article 86 § 1 and Article 70 § 1 of the Tax Ordinance Act (Ordynacja podatkowa)).
Modern technological solutions
The development of technology has made it much easier for business owners to record sales. Modern online cash registers offer many functions that can be particularly useful for seasonal businesses.
Online cash registers automatically send sales data to the Central Cash Register Repository (CRK). The data reaches the repository automatically, but you still have to issue daily and monthly fiscal reports on the cash register (§ 6(1)(3) and (4) of the Regulation of the Minister of Finance of 25 June 2025 on cash registers, Dz.U. 2025, item 845). For seasonal business owners, this means fewer formalities when transferring sales data.
Main functions of modern online cash registers:
- Automatic sending of data to the Central Cash Register Repository
- Integration with accounting and warehouse systems
- Analytical functions for monitoring sales
- Protection against the loss of fiscal data
- Remote monitoring of the cash register
Many online cash registers also offer analytical functions that can help business owners manage a seasonal business. Tracking sales in real time, analysing the most popular products and monitoring progress towards sales limits are functions that can make running the business much easier.
For business owners operating in different locations, portable online cash registers are also available. These devices make it possible to record sales in mobile trade, at fairs and in other places without permanent access to mains power.
Planning a seasonal business
Running a seasonal business effectively requires careful planning, especially as regards fiscal obligations. Business owners planning a holiday activity should analyse their obligations in advance and prepare to meet them.
The first step is to estimate the expected value of sales and check whether it will allow you to use the cash register exemption. Business owners starting their activity after 31 December 2024 can use the exemption if the expected value of sales does not exceed PLN 20,000 in proportion to the period of activity.
A business owner planning to run an ice cream parlour for the 4 summer months expects sales of PLN 15,000. Converted to a full year (15,000 × 12/4 = PLN 45,000), this exceeds the exemption limit, so they must use an online cash register from the start.
It is also important to determine the type of activity. If the planned activity will be food service, the business owner must prepare for the absolute obligation to use an online cash register, regardless of the value of sales.
Planning should also cover technical and organisational aspects. Choosing a suitable cash register, registering it, training staff and preparing customer service procedures all require time and careful preparation.
