Short-term holiday rental is becoming an increasingly popular form of business activity in Poland. Owners of flats, holiday cottages and guest rooms are more and more often deciding to let their properties to tourists. As the sector grows, however, important questions arise about tax obligations, particularly about recording sales on a cash register (kasa fiskalna).
The key question for business owners in holiday rental is whether the revenue from this activity must be recorded on a cash register. The answer is not clear-cut and depends on many factors, including the classification of the services provided, the level of turnover and the way payments are accepted.
Holiday rental most often involves providing services to private individuals who do not run a business. In such a situation the business owner must analyse their cash register obligations particularly carefully
The cash register rules provide for various types of exemptions that may apply to holiday rental. There are exemptions by type of activity, which cover specific kinds of activity, and turnover-based exemptions, which depend on the business owner's turnover. In addition, there are exemptions linked to the form of payment, which may be particularly important for holiday rental.
Exemption by type of activity for holiday rental
The basic legal act governing exemptions from the obligation to record sales on cash registers is the regulation of the Minister of Finance of 17 December 2024 (Journal of Laws (Dz.U.) 2024, item 1902), whose annex lists specific types of activity exempt from this obligation. Under § 2(1) of this regulation, certain activities, including services related to accommodation, are exempt from the obligation to record sales on cash registers in a given tax year.
This exemption applies no longer than until 31 December 2027, which means business owners can use it only for a limited period. The key element for applying this exemption is correctly classifying the holiday rental services provided under the appropriate heading of the Polish Classification of Products and Services (PKWiU).
The exemption by type of activity from the cash register for accommodation-related services applies until 31 December 2027. After that date the rules may change, so business owners should keep track of any amendments
The annex to the regulation lists only a few accommodation-related services that may benefit from the exemption. They are very specific categories of services which in most cases do not cover typical holiday rental. The exempt services include:
- Accommodation and related services provided by hotels, motels, guesthouses and other hotel establishments - but the exemption applies only to services provided by children's camps
- Other services of holiday and other short-stay accommodation without service - also only in the case of children's camps
- Other accommodation services with specific exclusions - but only if the entire service has been documented with an invoice
An important requirement for some categories of exempt services is the obligation to document the sale with an invoice. This condition is written directly into the relevant items of the annex to the regulation, which means the business owner must consistently issue invoices for all services provided.
The taxpayer is responsible for the correct statistical classification of services. In case of doubt, the business owner may ask the Statistical Office in Łódź (Urząd Statystyczny w Łodzi) for help, which will provide professional assistance with PKWiU classification
Classifying holiday rental under PKWiU
Correct classification of the services provided under PKWiU is fundamental for determining cash register obligations. In the case of holiday rental that is short-term, vacation or tourist in nature, these services are usually classified under PKWiU heading 55.20 as "Holiday and other short-stay accommodation".
This heading covers a wide range of short-stay accommodation services. It includes, among others, services provided by youth hostels, mountain shelters, chalets or holiday cottages. The classification also covers holiday homes to which guests have a shared right of use for a specified period each year.
The heading also includes other services of holiday and other short-stay accommodation without service. Particularly relevant is accommodation on a daily or weekly basis, with or without minimal accommodation-related services, in specially designated furnished rooms or premises.
PKWiU heading 55.20 covers accommodation in holiday facilities such as summer camps, holiday resorts, excursion houses, guest rooms, bungalows and training and leisure centres. The classification also covers rural farms providing agritourism services
Another element of this classification is accommodation during holidays in student houses, boarding schools and school dormitories. All these forms of accommodation share one feature - they are places where you can stay in specially prepared, furnished premises for a specified, usually short period.
The key information for business owners is that services classified under PKWiU 55.20 are not listed in the annex to the regulation as exempt from recording. The only exception is services provided by children's camps, which may benefit from the exemption.
| PKWiU classification | Type of service | Cash register exemption | Notes |
|---|---|---|---|
| 55.10.10.0 | Hotel services | Children's camps only | No invoice requirement |
| 55.20.19.0 | Holiday accommodation establishments | Children's camps only | Very limited application |
| 55.20 | Short-stay accommodation | No exemption | Covers most holiday rental |
| 55.90.1 | Other accommodation services | Partial exemption | Must be documented with an invoice |
Exemption based on the form of payment
Although most holiday rental services cannot use the exemption by type of activity, there are other ways to avoid the obligation to record sales on a cash register. One of the most important is the exemption based on the form of payment, set out in item 42 of the annex to the exemptions regulation.
This exemption is universal and does not depend on the classification of the services provided. Any business owner providing services to private individuals who do not run a business may use it, except for the services listed in § 4 of the regulation, provided they meet specific requirements on how payments are accepted.
The basic condition for this exemption is accepting payment only through the post office, a bank or a cooperative savings and credit union (SKOK). This means that all payments must be made to the taxpayer's bank account or to the taxpayer's account with the cooperative savings and credit union of which they are a member.
The exemption based on the form of payment requires that the records and payment documents clearly show which specific transaction the payment relates to. Each transaction must be precisely documented and identifiable
Proper documentation of payments is also an important requirement. The records and payment documents must clearly show which specific transaction the payment relates to. This means keeping detailed records that make it possible to link each payment to a specific rental service.
The most important rule of this exemption is receiving the entire payment for the service into an account. The condition "in full" refers to individual transactions: a service paid even partly in cash does not benefit from this exemption and – if the business owner has no turnover-based exemption – must be recorded on a cash register. Other services paid in full into an account may still benefit from the exemption.
In practice, this means that a business owner in holiday rental who wants to avoid a cash register must consistently inform all customers that only cashless payment is possible. What matters is whether the payment reaches the taxpayer's bank account – the Director of National Tax Information (Dyrektor Krajowej Informacji Skarbowej, KIS) found that the condition is also met by card payments accepted by booking platforms, where the funds reach the taxpayer's account and can be assigned to a specific booking (individual tax ruling of 26 June 2026, 0114-KDIP1-3.4012.357.2026.2.AMA). Payment in cash does not meet this condition. A separate way of paying for a stay is covered in our post on tourist vouchers for flood-hit areas.
Turnover-based exemption from the cash register
If a business owner cannot use the exemption by type of activity or the exemption based on the form of payment, they can still use the turnover-based exemption. This type of exemption is set out in § 3 of the exemptions regulation and covers businesses with low turnover.
The turnover-based exemption is available to business owners 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 – and it continues until this amount is exceeded in the current year. This limit applies only to sales to private individuals and flat-rate farmers and does not cover sales to other businesses.
In the case of holiday rental, which is usually provided to private individuals who do not run a business, all revenue from this activity will count towards the exemption limit. This means the business owner must carefully monitor their turnover so as not to exceed the permitted threshold.
The PLN 20,000 turnover-based exemption limit applies only to sales to private individuals and flat-rate farmers. Sales to other businesses do not count towards this limit and are not subject to the cash register obligation at all (Article 111(1) of the VAT Act)
Special rules apply if holiday rental starts during the tax year. If the business owner did not start this activity at the beginning of the year, the exemption limit must be calculated in proportion to the period of rental in that year.
A proportional calculation of the exemption limit is also mandatory for taxpayers who have only just started holiday rental to private individuals in the current year. Depending on the month in which the rental starts, you must calculate the proportion from the day you started providing rental services to private individuals until the end of the tax year.
Sample calculation for a business owner who started holiday rental on 1 March 2026:
- Number of days of activity: from 1 March to 31 December = 306 days
- Proportion: 20,000 × 306 ÷ 365 = PLN 16,767.12
- Exemption limit: PLN 16,767.12
Exceeding the turnover-based exemption limit does not mean an immediate obligation to introduce a cash register. The business owner loses the exemption only after two months following the month in which the limit was exceeded
Consequences of exceeding the exemption limit
Exceeding the turnover-based exemption limit does not cause an immediate loss of the exemption. The rules provide for a two-month grace period, which allows the business owner to prepare for introducing a cash register.
If the exemption limit is exceeded during the tax year, the taxpayer loses the exemption after two months following the month in which the limit was exceeded. This means the business owner has time to buy and start using a cash register.
Example: a business owner exceeded their exemption limit on 26 March 2026. In this situation they must introduce a cash register only from June 2026, which gives them more than two months to prepare.
Special rules apply to business owners who run holiday rental only during the holiday season. Even if such a business owner exceeds the limit after the end of the holiday season, they will not have to introduce a cash register immediately, provided they do not continue renting to private individuals in the current year.
Business owners who run seasonal holiday rental may avoid the obligation to introduce a cash register immediately if they exceed the limit after the end of the season. However, next year they will have to keep records before providing the first rental service
In such a situation the taxpayer will have to keep records next year, but only before providing the first rental service. This means they can prepare for the new season and introduce a cash register before starting the activity.
Obligation to keep records of non-register sales
Business owners using an exemption from the cash register are not completely free of record-keeping obligations. They must keep records of non-register sales (ewidencja sprzedaży bezrachunkowej), which are an alternative way of documenting turnover from sales to private individuals.
Records of non-register sales are a simplified way of documenting sales that does not require a cash register but provides an adequate level of control over the business owner's turnover. They must contain all relevant information about the transactions made.
The basic elements of records of non-register sales are:
- Date of sale
- Description of the service provided
- Gross sales value
- Amount of VAT (if applicable)
- Buyer's details (if available)
Records of non-register sales must be kept systematically and in chronological order. Each transaction should be entered on the day it takes place, and entries must be made no later than the end of the day following the sale
Keeping records of non-register sales requires particular care, because they are the basis for settling VAT and income tax. Errors in the records may lead to incorrect tax settlements and related consequences.
Storing the records of non-register sales is also important. Like other accounting documents, they must be kept until the tax liability becomes time-barred – as a rule, for 5 years from the end of the year in which the tax payment deadline passed (Article 86 § 1 and Article 70 § 1 of the Tax Ordinance Act (Ordynacja podatkowa)).
Recording holiday rental sales on a cash register
Taxpayers who cannot use any of the cash register exemptions when providing holiday rental to private individuals must record their sales on a cash register. This obligation covers all revenue from holiday rental. A register can also be needed for one-off transactions, as we explain in selling fixed assets and cash registers.
Recording on a cash register must comply with the applicable rules and cover all transactions from sales to private individuals. A fiscal receipt (paragon fiskalny) for each rental service is issued at the time of sale, no later than when payment is accepted (§ 6(1)(1) of the regulation of the Minister of Finance of 25 June 2025 on cash registers, Journal of Laws (Dz.U.) 2025, item 845).
Pay particular attention to recording advance payments, deposits and prepayments received. Receiving them gives rise to a VAT tax point, which means they must be recorded on the cash register before the service is provided: an advance in cash – when it is received, and an advance by bank transfer – promptly after it is credited to the account, no later than at the end of the month (and if the service is provided earlier – no later than when it is provided).
Advance payments, deposits and prepayments received from customers must be recorded on the cash register before the service is provided – cash payments when received, bank transfers promptly after they are credited to the account (§ 6(1)(2) of the regulation on cash registers). This is because the VAT tax point arises as soon as the payment is received, regardless of when the service is provided
The cash register report is the basic document confirming the business owner's turnover. It must be shown in the records part of the JPK_V7 file (VAT return with records, SAF-T file) with the appropriate RO code, which indicates that it comes from a cash register.
Recording on a cash register also requires proper coding of transactions in accounting systems. Each fiscal report must be properly booked and marked with the appropriate transaction code to ensure correct tax settlements. We book fiscal reports from the till for clients of our bookkeeping services.
Practical aspects of bookkeeping in holiday rental
Proper bookkeeping of holiday rental transactions requires knowledge of the specifics of this activity and of the applicable tax rules. Business owners must pay particular attention to properly documenting all transactions.
When using an accounting system, the fiscal report with the correct transaction code should be booked as sales revenue. As the buyer, select the "no counterparty" option, because the sales are made to private individuals who do not run a business.
Documents should be numbered systematically and chronologically. A sample designation may be ŁRO DD/MM/RRRR, where ŁRO stands for the combined periodic report (łączny raport okresowy) and DD/MM/RRRR is the date the report was issued.
A business owner running holiday rental in the summer season received payments only by bank transfer. This allowed them to use the exemption based on the form of payment and they did not have to record sales on a cash register. However, the service for which they accepted one cash payment no longer benefited from this exemption – and because they had earlier exceeded the turnover-based exemption limit, they had to record it on a cash register. The other services paid in full by bank transfer remained exempt.
In accounting systems it is also important to mark the type of sale correctly for the JPK_V7 file. When booking a periodic cash register report, choose the RO code, and when booking records of non-register sales - the WEW code.
Pay particular attention to booking on time. All fiscal reports should be booked on an ongoing basis, no later than the deadline set by the tax rules. Delays in bookkeeping may lead to problems with tax settlements.
Checking and reviewing tax obligations
Business owners running holiday rental should regularly review their cash register obligations. Changes in turnover, in the way payments are accepted or in the classification of the activity may affect the right to use the exemptions.
Monitoring turnover is particularly important for the turnover-based exemption. Business owners should keep ongoing records of revenue from sales to private individuals so that they can assess at any time whether they are approaching the PLN 20,000 limit.
The PKWiU classification also needs regular review. Growth of the business or a change in the nature of the services provided may affect the classification and therefore the right to use exemptions by type of activity.
Business owners should keep detailed documentation justifying the use of a specific cash register exemption. In the event of a tax audit, such documentation will be needed to show that they acted correctly
Documentation justifying the use of a specific exemption is also important. Business owners should collect all documents confirming that the exemption conditions are met, such as confirmations of cashless payments, the PKWiU classification or turnover records.
If in doubt about the classification of the activity or the use of exemptions, business owners can apply for an individual tax ruling (KIS) to the Director of National Tax Information. Following such a ruling cannot harm the taxpayer (Article 14k § 1 of the Tax Ordinance Act).
