VAT-R 2026
how to fill in the Polish VAT registration form step by step
VAT-R is the registration form for Polish VAT payers — both active and exempt — and for businesses registering for intra-EU transactions (VAT-EU). We explain who must submit it in 2026, when, which fields in parts A-C to complete, and what consequences late or incorrect registration brings. Especially useful for foreign founders of JDG (sole proprietorship) and Sp. z o.o. (limited company) in Poland.
Who must file VAT-R in 2026
The VAT-R form (Registration Declaration for Goods and Services Tax) is the basic document identifying an entrepreneur for VAT purposes. The filing obligation covers three groups of taxpayers:
- Taxpayers who waive the subjective VAT exemption — companies that voluntarily wish to become active VAT payers, even though their turnover has not yet exceeded the annual limit of 200,000 PLN.
- Taxpayers who lose the right to exemption — when turnover in a given year has exceeded 200,000 PLN, or when sales of services/goods requiring registration regardless of turnover have begun (legal services, advisory, supplies of building land, new means of transport).
- Taxpayers registering for VAT-EU — anyone planning to carry out intra-EU transactions (WDT, WNT, supply and acquisition of services under art. 28b of the VAT Act).
The legal basis is art. 96 of the Polish VAT Act of 11 March 2004. The taxpayer submits the declaration to the head of the tax office competent for the place of residence (natural persons) or registered seat (companies, legal persons).
When to file VAT-R — statutory deadlines
The deadline depends on the taxpayer's situation:
| Situation | VAT-R deadline |
|---|---|
| Waiving subjective exemption (200,000 PLN limit) | Before the start of the month in which the taxpayer waives exemption |
| Beginning VAT-taxable sales (e.g. legal services) | Before the first taxable act |
| Loss of exemption rights (exceeding 200,000 PLN) | Before the day exemption is lost |
| Registration for VAT-EU (before first WDT/WNT) | Before the first intra-EU transaction |
| Data update (address, account, taxation form) | Within 7 days of the change |
Late registration means losing the right to deduct input VAT on purchase invoices for the period before registration, and — for WDT — losing the right to the 0% rate (see article WDT 2026).
Part A — place of filing and purpose
Part A specifies the tax office that receives the declaration and the purpose of filing.
Field 4 — head of the tax office: enter the full name of the office competent for your address:
- Natural persons (JDG, unregistered activity) — office competent for residence address.
- Sp. z o.o., spółka komandytowa, SA — office competent for the company seat.
- Spółka cywilna — office competent for the partnership seat (single NIP).
Field 5 — purpose of filing: select one option:
- 1 — registration — first submission, when the taxpayer was not previously registered for VAT,
- 2 — update — any data change (address, bank account, settlement frequency, VAT-EU registration/deregistration, change from active to exempt status, etc.).
A common mistake is selecting "registration" instead of "update" when changing data — this causes the declaration to be rejected. Check your status in the White List of VAT taxpayers before filling in.
Part B — taxpayer identification data
Part B contains the identifying data. Completion depends on the legal form:
B.1 — type of taxpayer (field 7):
- 1 — natural person (JDG, self-employed activity, liberal profession),
- 2 — taxpayer other than a natural person (capital companies, general partnerships, partnership companies, foundations, associations).
B.2 — natural person data (fields 8-14): surname, first names, date of birth, PESEL, father's and mother's first names. NIP is entered in position 1 on the first page.
B.3 — company/legal person data (fields 9, 15-17): full name, abbreviated name, REGON, KRS (if entered). Seat address in fields 18-29.
If you run a JDG and your registered address differs from your residence, enter both addresses — residence in field 18, business address in "other addresses". The office contacts you at your residence address (natural persons) or company seat (companies).
Part C.1 — registration as an active VAT payer
Part C.1 concerns registration as an active VAT payer. Complete this part if:
- You waive subjective exemption (200,000 PLN limit) — field 30.
- You lose the right to exemption (exceeded the limit) — field 31.
- You waive objective exemption (e.g. medical, educational services — when you also provide taxable ones) — field 32.
- You perform activities excluding exemption (art. 113 sec. 13 — legal, advisory, jewelry services, certain supplies) — field 33.
- You begin performing taxable activities — field 34.
In fields 35 and 36 you provide the date from which you waive exemption or lose the right to it. This is a key date — from it counts the obligation to issue VAT invoices, keep JPK_V7 records and remit tax.
Settlement frequency (fields 37-38): monthly (standard) or quarterly (small taxpayers whose previous year's turnover did not exceed 1,200,000 EUR). The choice affects JPK_V7M / JPK_V7K filing deadlines and VAT payment.
Cash method for VAT (field 39): applies to small taxpayers. Instead of settling VAT on the invoice date, you settle on the payment date.
Part C.2 — registration as exempt VAT payer
Part C.2 concerns taxpayers who want to be formally registered as VAT-exempt (although there is no such obligation). Why? To:
- Be able to register for VAT-EU (exempt taxpayers can and often must — e.g. when exceeding the 50,000 PLN WNT limit),
- Obtain confirmation of status in the taxpayer register,
- Simplify verification for contractors (the White List also contains exempt taxpayers).
Select field 40 (exemption under art. 113 sec. 1 or 9 — 200,000 PLN limit) or field 41 (objective exemption, art. 43 sec. 1 — medical, educational, financial services).
Remember: an exempt taxpayer does not issue VAT invoices, but bills or invoices without VAT (with the annotation "exempt under art. 113 sec. 1/9 of the VAT Act"). They do not file JPK_V7 — unless they register for VAT-EU and carry out WNT or import of services (then they file VAT-8 or VAT-9M).
Part C.3 — VAT-EU registration (fields 58-69)
Part C.3 concerns registration for intra-EU transactions. It is mandatory if you plan to perform WDT, WNT, or supply/acquire services settled under art. 28b of the VAT Act.
Three registration paths:
- Field 58 — active VAT payer: ticked by every active VAT payer who intends to carry out EU transactions (sales, purchases, services).
- Field 59 — VAT-exempt making WNT: ticked by an exempt taxpayer who exceeded the 50,000 PLN WNT limit during the tax year, or voluntarily registers before exceeding it.
- Field 60 — VAT-exempt purchasing services under art. 28b: ticked by an exempt taxpayer who buys services from EU contractors (e.g. IT, marketing, advisory services) — the tax settlement falls on the purchaser.
Field 68 — start date of intra-EU transactions: the date you plan your first WDT/WNT/service. After registration, you gain the right to use your NIP with prefix PL.
A detailed guide to this part is in the article VAT-EU — registration via VAT-R (part C.3) 2026.
Most common VAT-R mistakes
- Wrong purpose of filing — selecting "registration" instead of "update" when changing data. Result: the declaration is rejected.
- Missing bank account on the White List — since 2020, active VAT payers must have an account entered in the register. No account = no VAT deduction for the contractor on payments above 15,000 PLN.
- Wrong field in part C.1 — e.g. ticking field 30 (waiver of exemption) instead of 31 (loss of rights) when exceeding the limit.
- No VAT-EU registration before first WDT — result: loss of the right to 0% rate, an additional 23% VAT from your own pocket.
- Invalid start date — e.g. a past date the office cannot verify. VAT-R has no retroactive force.
- Missing attachments — companies: current KRS extract, articles of association. JDG of foreigner: PESEL UKR / Karta Polaka / passport.
How to submit VAT-R — channels
VAT-R can be submitted via three channels:
- Electronically with a qualified signature — the fastest route (registration in 3-7 working days). Requires a valid electronic signature. You can submit via e-Tax Office (e-Urząd Skarbowy) or an advisor's application.
- Trusted profile via e-Tax Office — a cheaper alternative to the qualified signature, available to natural persons.
- Paper form at the tax office — in person or by registered mail. Slower (10-21 days), but sometimes necessary (e.g. companies without an electronic signature).
When founding a JDG via CEIDG, the VAT-R can be submitted together with the CEIDG-1 application — this greatly simplifies the process.
After positive review you will receive: a) registration confirmation (VAT-5) — since 2015 issued on request for 170 PLN, in practice unnecessary; b) entry on the White List; c) the PL prefix on your NIP if VAT-EU registration was selected.
Frequently asked questions
Do I have to file VAT-R if I run a JDG selling only to consumers in Poland?
No, if you use subjective exemption (turnover up to 200,000 PLN annually) and do not provide services excluding exemption (legal, advisory, jewelry). You can run the business without VAT registration, issuing bills or invoices without VAT.
What happens if I file VAT-R after performing the first taxable activity?
You lose the right to deduct input VAT on purchase invoices for the period before registration. The office may also impose a 30% sanction on the amount of tax you should have settled. That's why VAT-R is filed before the first taxable act.
Can a VAT-exempt taxpayer also file VAT-R?
Yes — if they want to register for VAT-EU (when WNT exceeds 50,000 PLN or when buying services under art. 28b), or to be formally registered as exempt (part C.2). Without VAT-EU registration, you cannot use the 0% rate on WDT or deduct VAT on imported services.
How much does VAT-R registration cost in 2026?
Filing the VAT-R itself is free. The 170 PLN fee applies only to the registration confirmation (VAT-5) on the taxpayer's request — since 2015 such confirmation is unnecessary because the status can be checked in the White List.
Can I change my VAT settlement frequency (monthly/quarterly) after registration?
Yes — file an update VAT-R, selecting 'update' in field 5 and changing field 37 or 38. The change takes effect from the first day of the next settlement period (month or quarter).
Need help with VAT registration?
The Księgowość 365 team — Andrzej Szulakowski and Stanislav Ozarchuk — has been serving entrepreneurs across Poland for more than 5 years in VAT, VAT-EU, intra-EU transactions and KSeF compliance. We help both active VAT payers and exempt businesses entering EU sales or purchases.
We will fill in the VAT-R on your behalf, prepare attachments, submit the form electronically with our qualified signature, and represent you before the tax office. We work with JDG, Sp. z o.o. and foreigners founding a business in Poland (PESEL UKR, Karta Polaka, residence permits).
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Anna specializes in VAT, KSeF, intra-EU transactions and e-commerce support for small and medium businesses in Poland.