A familiar story. Someone registers an Sp. z o.o. in April, plans to launch by autumn, and then the plans change. The company sits there: no invoices, no staff, no movement on the account. Eighteen months later a letter arrives from the tax office, and it turns out that a company which did nothing at all can be fined five figures.
The problem is that the tax office looks at registrations, not turnover. While you sit in the VAT register, the return is due. While the Sp. z o.o. sits in the KRS, CIT-8 is due. A zero in the income column changes none of it.
Which nil filings are mandatory, and when
An active VAT payer files a nil JPK_V7 by the 25th for every month or quarter. An Sp. z o.o. files CIT-8 by 31 March regardless of turnover. Financial statements are prepared by 31 March, approved by 30 June, and filed with the KRS within 15 days of approval. The annual PIT for a sole trader is due by 30 April.
The full deadline map:
| Filing | Who files | Deadline | Required at zero |
|---|---|---|---|
| JPK_V7M / V7K | active VAT payer | by the 25th | yes |
| ZUS DRA | active JDG | by the 20th | yes |
| PIT-36 / 36L / 28 | JDG | by 30 April | yes |
| CIT-8 | Sp. z o.o. | by 31 March | yes, no exceptions |
| Financial statements (preparation) | Sp. z o.o. | by 31 March | usually yes, see below |
| Approval of the statements | shareholders' meeting | by 30 June | yes |
| Filing with the KRS | Sp. z o.o. | 15 days after approval | yes |
The dates apply to a tax year matching the calendar year, which covers roughly 99% of foreign-owned companies.
What silence costs: fines calculated from the 2026 minimum wage
Polish penalties are pegged to the minimum wage, and from 1 January 2026 that is 4,806 PLN gross. Which gives concrete numbers.
Failing to file a return is a fiscal offence under art. 56 § 4 of the Fiscal Penal Code. The fine runs from one-tenth to twenty times the minimum wage: 480.60 to 96,120 PLN. On the spot an inspector may issue a penalty notice, capped at twice the minimum wage - 9,612 PLN.
If the non-filing left the budget short by more than five times the minimum wage - more than 24,030 PLN - the act is reclassified as a fiscal crime. There the fine runs up to 720 daily rates, with a single rate starting at 160.20 PLN.
The nastiest consequence is not financial at all. Under art. 96(9a)(2) of the VAT Act the tax office removes a company from the VAT register if no returns arrive for three consecutive months (or one quarter under the quarterly regime). Once removed, your NIP shows up on the white list as inactive. Counterparties notice before you do: they check you before every payment of 15,000 PLN or more, because otherwise they lose the right to deduct it. Getting back into the register is a separate procedure with explanations attached.
The carve-out few accountants check: art. 12(3b)
Here is the part almost nobody verifies, and it saves a client about fifteen hundred zloty a year.
As a general rule an Sp. z o.o. must prepare financial statements every year, have them approved, and file them with the KRS. But art. 12(3b) of the Accounting Act permits not closing the books - and therefore not preparing statements and not filing them - where two conditions hold simultaneously:
- the activity was suspended for the entire financial year
- no event with property or financial consequences occurred during that year
The second condition disqualifies more cases than the first. Depreciation write-offs are an event with property consequences. Accrued interest on a shareholder loan is one too. Account maintenance charged against the remaining balance arguably is as well. This cannot be judged by eye: we pull the books and check every entry for the year.
CIT-8 remains due either way. There is no exemption from it for a suspended or entirely empty company - art. 27 of the CIT Act requires a return for every tax year.
JDG: suspension became indefinite in 2026
For sole traders the maths is different, and in 2026 it got noticeably better.
A suspended JDG files no JPK_V7 and pays no ZUS contributions - the entrepreneur is deregistered from social insurance. And the key change: the 24-month cap for a JDG in CEIDG has been lifted. Activity can now be suspended indefinitely, with a minimum period of 30 days. Previously you had to either resume or close after two years.
What remains during suspension: the annual PIT for the suspension period, due by 30 April. One caveat - if an import of services or an intra-EU acquisition of goods occurred during the suspension, the JPK_V7 obligation returns for that month.
An active JDG with no income is the worst of the options. Everything is due: JPK_V7, ZUS DRA by the 20th, contributions under the general rules, and the annual PIT. Since the health-contribution reform the base is calculated from income, so DRA effectively goes in every month. If there is no work and none coming, suspension is almost always cheaper than paying contributions into thin air. The full "close or suspend" calculation is here.
Two years overdue? The mechanism is called czynny żal
Good news here: overdue filings are almost always fixable, provided you come forward yourself.
Czynny żal under art. 16 of the Fiscal Penal Code is a voluntary notification to the tax office that you breached an obligation, submitted together with the filings themselves and payment of any arrears. Filed correctly, it means the penalty is not imposed at all. Not reduced - not imposed.
One condition, and it is strict: the notification must go in before the tax office starts inspection activities or learns of the breach from another source. After the first summons arrives, czynny żal no longer works and only the size of the fine is negotiable.
So when a client opens with "I haven't filed anything for two years", we do not start with excuses - we start a clock. The order runs: obtain access to the e-Tax Office, pull the filing history, map every gap, prepare the disclosure plus the full pack of overdue filings, and send it all in one go. In parallel we correct whatever was filed with errors.
KSeF applies to dormant companies too
From 1 February 2026 every taxpayer must be able to receive structured e-invoices through KSeF, even those issuing none.
The duty to issue invoices in KSeF phases in:
- from 1 February 2026 - companies with 2024 sales above 200 million PLN
- from 1 April 2026 - all other entrepreneurs
- from 1 January 2027 - small businesses issuing under 10,000 PLN gross of invoices a month
For a company with no turnover the takeaway is simple: set up KSeF access and authorisations in advance. Working it out on the day of your first deal costs a week. We covered the system in detail in our KSeF breakdown.
So: file zeros, suspend, or close?
Fifteen minutes of arithmetic, and the answer depends on the legal form and on your plans.
JDG with no work for a while - suspend. Indefinite since 2026, ZUS and JPK_V7 fall away, only the annual PIT remains. Resuming takes one CEIDG filing.
Sp. z o.o. pausing for a year or two - suspend, then test the art. 12(3b) conditions. If both hold, you save the annual statements. CIT-8 stays. Note that for KRS-registered companies the 24-month cap survives; indefinite suspension is not available.
Sp. z o.o. with no plans at all - liquidate. It costs once, whereas nil filings drip on for years, and every year carries the risk that someone forgets a deadline. We compare selling against liquidating in a separate piece.
No need for VAT - deregister with VAT-Z rather than going quiet. It is free and removes the most frequent obligation on the list.
Common questions
Do I have to file JPK_V7 if I sold nothing at all? Yes, if you are an active VAT payer. The duty grows out of your status, not your turnover: the return goes in by the 25th with zeros in every field. The only exception is a period of formal suspension, and even then only if there was no import of services or intra-EU acquisition.
Can the tax office simply close the company for non-filing? It will remove you from the VAT register after three months of silence. Companies are not deleted from the KRS that way, but the court does have a mechanism to dissolve a dormant entity without liquidation where it files no statements and ignores summonses. It is not worth reaching that point: the procedure runs without you, and the board's liability remains.
What does it cost to have a lawyer file a nil return? With us, from 800 PLN per report, one-off, no subscription. CIT-8 together with the financial statements and the e-KRS filing runs from 1,500 PLN, since that adds the shareholder resolutions and the structured XML. A full-year package for a dormant company runs from 2,500 PLN. Back-filing with a voluntary disclosure runs from 1,200 PLN.
Do you need a power of attorney to file on my behalf? Yes, a UPL-1 for electronic tax filings and ZUS-PEL where needed. UPL-1 carries no stamp duty and is signed via ePUAP, a qualified signature, or on paper.
Nil filings are the dullest and cheapest part of running a Polish company. They turn expensive at exactly the point they get ignored: 480 PLN of exposure becomes 96,120, removal from the VAT register breaks your dealings with counterparties, and reinstatement takes months.
Tell us the legal form and the month the filings stopped, and we will map the exact obligations and quantify the exposure in a single consultation.
This article is informational. Tax consequences depend on the specific facts - consult a lawyer or accountant for an individual assessment.