Unregistered activities in Poland

Unregistered activities (Polish. działalność nierejestrowana(also known as a "probusiness") is a special legal tool that allows an individual to generate income from small activities without officially registering the business. If certain conditions are met, it is possible to avoid bureaucratic formalities, contributions to social funds and advance tax payments. Below we will consider what this format of activity is, who is entitled to use it, as well as its advantages and limitations - especially in the context of foreign nationals

What is unregistered activity?

Unregistered activities allow small businesses to operate unincorporated in the Entrepreneurs' Register (CEIDG), without being registered with the tax and statistical authorities. The main restriction is revenue must not exceed 75% minimum wage per month. In 2025, the minimum monthly wage in Poland is 4666 zł gross, so the income threshold for unregistered activities is as follows 3499,50 zł gross per month. If the income exceeds this limit in at least one monthWithin 7 days, it is necessary to register a full-fledged business (e.g. registering a sole proprietorship). jednoosobowa działalność gospodarcza in CEIDG, or open a spółka z o.o.). Otherwise, the activity will be considered as violating the law on entrepreneurship, which is fraught with fines and additional taxes.

In addition to the income limit, there are other conditions for running an unregistered business:

• Just an individual. Only a private person can use this instrument; conducting through a civil partnership (spółka cywilna) is excluded.
• No registered business in the last 60 months. The person must not have been in business for at least 5 years prior to the commencement of the unregistered activity. (Allowed if there was a firm, but its activity was officially suspended for the specified period.)
• Lack of licensable activities. Unregistered activities cannot cover types of business that require special permits or licences (concessions). For example, it is impossible to engage without registration in something that requires a licence (trade in alcoholic beverages, etc.) or is obliged to have a cash register from day one. In particular, some services (taxis, car transport, car repairs, hairdressing salons, etc.) are required by law to be equipped with a cash register regardless of turnover - even in the format of Działalność nierejestrowana such activities must fulfil these requirements.
• The income limit is 75% of the minimum wage. As noted, the monthly revenue must not exceed the established threshold (3499.50 zł in 2025). If exceeded, registration of a full-fledged business within a week is mandatory.

It is important to emphasise that unregistered activities is not considered an entrepreneurial activity legally (according to Article 5 of the "Business Constitution" - Prawo Przedsiębiorców), as long as the above criteria are met. It's a kind of "test mode" business, giving the opportunity to try out a business idea in practice without setting up a company.

Example: many small services or hobbies, such as repairing bicycles in one's own workshop (illustration), can be legally performed as unregistered activities - provided that the monthly income does not exceed a set limit.

Who can benefit from unregistered activities?

Polish citizens are entitled to use this instrument on a general basis, provided that all conditions are met (income limit, no business for 60 months, etc.). However, for foreign nationals there are additional restrictions. Amendments to the legislation, which came into force on 1 June 2025, have significantly narrowed the circle of foreigners entitled to operate without registration. According to the law, unregistered activity is available only to foreigners with a certain residence status in Poland:

• Permanent residence permit (permanent stay, zezwolenie na pobyt stały).
• EU long-term resident card (right of permanent residence within the European Union).
• "EU Blue Card (Blue Card, a highly skilled work permit), as well as the associated temporary residence permit for the long-term mobility of the Blue Card holder.
• Temporary residence permit for family reunification, study or research purposes (residence card for family reunification; student or researcher on the basis of appropriate authorisation).
• Refugee status either additional security (asylum), as well as temporary security (e.g. for Ukrainian citizens during the war).
• Residence permit by humanitarian reasons or in tolerance regime (permission to stay on humanitarian grounds).
• A residence card due to marriage to a Polish citizen (residence permit for spouses of Polish citizens).
• Temporary residence permit for the purpose of entrepreneurial activity (business visit card).
• Pole card (Karta Polaka) is a Polish map of origin.
• Nationality countries enjoying the right of free enterprise in Poland: EU/EEA citizens, SwitzerlandAs well as under certain international treaties, the following are also relevant. US citizens.
• Ukrainian citizenswho are legally residing in Poland and who have received PESEL number (during the period of the special law). (This applies mainly to Ukrainians arriving after February 2022 who have been granted temporary asylum and special rights in Poland).

If a foreigner does not have one of the listed statuseshe's cannot legally conduct unregistered activities. For such persons, the only way to legally engage in business is to register a full-fledged company (e.g. open a sp. z o.o. or find a Polish partner) or to obtain another authorised form of employment.

❗ Important for foreigners: Even if there is a suitable status, one nuance must be taken into account. If in fact the foreigner's activities are carried out under a civil law contract (e.g., you have concluded umowa zlecenie or a contractual agreement with a shop to supply its products), then may require a separate authorisation from the voivode to work. Simply put, the state considers such a situation as a foreigner performing customised work, which requires a licences (work permit), similar to regular employment with an employer. The process of obtaining a voivodeship permit is time-consuming and bureaucratically complicated, and it is not economically viable for low-income activities. Therefore, conducting unregistered activities makes sense mainly when providing services or selling goods directly to end customerswithout formal contracts with Polish companies. If your microbusiness involves working through contracts with organisations, this scheme may require additional permits and loses its attractiveness.

Example: You mould clay souvenirs and sell them directly to customers at a fair - this can be done as an unregistered activity and no work permit is required. But if you have agreed with a shop that it will buy a batch of souvenirs from you under a contract and sell them - formally you enter into legal relations under a contract of work. In this case, even with the right to unregistered activity, the foreigner will need to either obtain the voivode's permission to perform this activity or have grounds for exemption from such permission. Such requirements noticeably limit the foreign entrepreneur's freedom of action.

Advantages of unregistered activities

The Działalność nierejestrowana format is attractive to aspiring entrepreneurs due to a number of obvious advantages:

• There is no obligation to register a business. It is not necessary to enter yourself in the CEIDG register as an entrepreneur, to notify the tax office and the General Statistics Office of GUS about the start of the activity. Also NIP and REGON numbers do not need to be obtained (tax identifier and statistical number of the firm).
• Lack of contributions to ZUS. You do not have to pay monthly social contributions for pension and health insurance (Zakład Ubezpieczeń Społecznych) - savings can amount to several hundred zlotys per month.
• Exemption from VAT and advance taxes. For small incomes, the entrepreneur is exempt from paying VAT (VAT) and from making monthly or quarterly income tax advances. Important: The final income tax is still paid once a year, when filing the PIT declaration (see below), there is simply no obligation to pay it in advance. Also in case of low turnover up to ~200 thousand zł per year you can use the exemption from VAT registration, which is usually the case for unregistered activities.
• Simplified Accounting. There is no requirement to keep full-fledged accounting records or a book of income and expenses like an entrepreneur. It is sufficient to keep a simple sales journal to control revenue, and tax is calculated on a year-end basis.

Due to the absence of insurance premiums and administrative procedures, the threshold for entry into the business is minimal. You can start earning almost immediatelywithout spending time and money on registration. This is especially convenient for self-employment, hobbies or testing business ideas.

Obligations in case of unregistered activities

Notwithstanding the exemption from a number of duties of an entrepreneur, you can't avoid reporting completely. While conducting unregistered activities, an individual must comply with the following requirements:

• Maintaining revenue records. You need to record your sales and receipts in a simplified sales log (revenue accounting). It is usually sufficient to record the amount of revenue by day and month in a notebook or table. This is necessary both for your own assurance that the limit is not exceeded and for tax reporting. In the journal, as a rule, the date of sale, the amount per day and the cumulative total - the total revenue from the beginning of the month and year should be entered.
• Annual Tax Return (PIT-36). By 30 April of the following year, a personal income tax return must be submitted to the tax inspectorate (form PIT-36), indicating income from unregistered activities for the year. You do not have to pay income tax monthly or quarterly, but at the end of the year, the profit earned will be taxed at general rates (progressively 12%/32%). There is a special section in the declaration "Działalność nierejestrowa"which reflects the amount of income and documented expenses (if any) to calculate the taxable base.
• Respect for consumer rights. Even without being formally an entrepreneur, you are acting as a seller of goods or services, so are obliged to comply with the provisions of the Consumer Protection Act. The buyer is entitled to guarantees, return and exchange of goods, full product information, etc., as if buying from a registered company. Failure to comply with these rules may result in complaints to the UOKiK (Office for Competition and Consumer Protection) and fines.
• Issuance of a cheque or invoice on request. As a general rule, a participant in unregistered activities exempted from mandatory cheque and invoice issuance for each sale. However, if the buyer (customer) has requested a document, you will are required to provide a cheque or invoice. You do not need to buy a cash register as long as your annual turnover does not exceed 20,000 PLN and if the type of activity is not included in the list of activities that require a cash register. In most cases it is sufficient to issue an invoice manually. If the client requests an invoice, it can be issued as a "simplified" invoice, indicating a minimum of information (name, date, service, amount) - the tax number (NIP/PESEL) and address do not have to be indicated. The customer may request an invoice within 3 months from the end of the month of purchase of goods/services, in which case the seller must issue the document within 7 days of the request.

In general, the requirements are fairly uncomplicated and boil down to maintaining basic order in accounting. These duties are not time-consuming, but they should not be neglected. For example, a lack of record keeping or an "unreadable" sales log could lead to the IRS determining the amount of your income at their discretion in the event of an audit, which is clearly undesirable.

IMOSTA Group's position: temporary solution, not a long-term strategy

Many aspiring entrepreneurs ask us: "Is it possible to start with an unregistered activity and then open a company when the business is going?" Practice shows that this approach is possibleIt is important to be sober about its scope and not to delay the transition to a full-fledged format. Our experience of working with clients allows us to draw several conclusions:

• Unregistered activities are only suitable for very small turnover and simple operations. It's a kind of self-employment on a trial basisIf you are planning a serious commercial project that will potentially bring in more than a few thousand zlotys a month, it is better to immediately consider the steps of registering a business. If you are planning a serious commercial project that will potentially bring in more than a few thousand PLN per month, it is better to immediately think through the steps of registering a business.
• For foreigners, this instrument has severe restrictions. As we have discussed above, the right to an unregistered business is not available to all foreign nationals and is also complicated by work permit issues. Therefore, it is often unrealistic to expect to build a long-term business in Poland based only on the Działalność nierejestrowana format.
• A mistake in adhering to a limit or accounting can be costly. If you exceed the income limit and do not register a company in time, or do not keep a sales journal properly, the regulatory authorities may charge you additional taxes and contributions retroactivelyIt is not worth the potential risks of saving money on accounting - it is better to establish income control immediately. Saving on accounting is not worth the potential risks - it is better to immediately establish control over income and timing.

Thus, we view unregistered activity as more of a A temporary solution or a way to test a business ideabut not as a basis for a long-term and large-scale business. When your activity starts to grow steadily, serious clients, partners or employees appear, you can't do without a full-fledged registration.

Bottom line

Unregistered activities in Poland - is a convenient start-up tool that allows you to try your hand at business without unnecessary formalities. It gives a certain freedom and reduces costs at the initial stage. However, this format has significant limitations in terms of scale and accessibility for foreigners. If you are planning to build sustainable business with growth prospectswork with partners and employees, reach the revenue above ~3-4 thousand zł per month -. registration will be required and the choice of a full-fledged organisational and legal form.

Remember. you can't stay in the shadows indefinitely: successful development will inevitably lead to exceeding the limits and the need to legalise the activity. It is better to prepare for this step in advance by choosing the best format (sole proprietorship, spółka z o.o., etc.) and taxation regime.

📌 IMOSTA Group provides comprehensive assistance to entrepreneurs and foreigners in Poland. We help to understand all the nuances of Polish law - from choosing a business form and obtaining the necessary permits to bookkeeping and tax optimisation. Come in for a counselling session: we will review your situation and advise you on the best way to legal and profitable doing business in Poland.

Sources: The legal framework and up-to-date information on unregistered activities are taken from official Polish resources and expert publications, as well as practical explanations prepared on the basis of the experience of IMOSTA Group consultations