A new health-contribution model (składka zdrowotna) is in force in Poland from 1 January 2026. It's the largest reform of entrepreneur tax burden since 2022 (Polski Ład). For most foreign-owned JDGs and single-shareholder Sp. z o.o.'s, the annual burden falls by PLN 2,000–8,000. But not for everyone — for some high-income groups the contribution went up. Here's the breakdown by business form.
What changed on 1 January 2026
Before 2026, the health contribution for JDGs was 9% (progressive scale) or 4.9% (flat tax) of income — no cap, no minimum. It produced a paradox: an entrepreneur earning PLN 250,000 paid more health contribution than an employee on a regular contract with the same salary.
From 2026, the rules are rewritten:
- Fixed minimum for all JDGs — 9% of 75% of the minimum wage. With a 2026 minimum of PLN 4,806 gross, that's PLN 324.40/month (PLN 3,893/year).
- Progressive cap — above a certain income, the contribution stops growing. For the 19% flat rate the cap is around PLN 1,500/month.
- Sp. z o.o. — unchanged: a board member pays 9% of the board-member salary (if appointed by a shareholder resolution).
- Estonian CIT — still exempt from the health contribution during the reinvestment phase.
What a JDG now pays
It depends on the taxation form. Two most popular among foreigners — flat 19% and ryczałt 12%.
JDG on flat 19%
| Annual income (PLN) | 2025 contribution (4.9%) | 2026 contribution | Difference |
|---|---|---|---|
| 60,000 | PLN 245/m | PLN 324/m (minimum) | +79/m |
| 120,000 | PLN 490/m | PLN 490/m | 0 |
| 240,000 | PLN 980/m | PLN 980/m | 0 |
| 500,000 | PLN 2,042/m | PLN 1,500/m (cap) | -542/m |
| 1,000,000 | PLN 4,083/m | PLN 1,500/m | -2,583/m |
Low-income JDGs pay slightly more (the minimum). High-income — significantly less (the cap). Break-even sits around PLN 240,000 income.
JDG on ryczałt 12%
Smaller changes — ryczałt already paid contributions in fixed brackets keyed to revenue.
| Annual revenue (PLN) | 2025 | 2026 |
|---|---|---|
| Up to 60,000 | PLN 419/m | PLN 324/m (new minimum) |
| 60,000 – 300,000 | PLN 698/m | PLN 698/m |
| Over 300,000 | PLN 1,256/m | PLN 1,256/m |
The main saving on ryczałt is in the lowest bracket (-PLN 95/month).
Sp. z o.o. — what changes
Short answer: nothing, except one nuance.
A Sp. z o.o. board member pays the health contribution only if appointed by a shareholder resolution with remuneration. The rate is 9% of the board-member salary. Unchanged.
What's new: from 2026, ZUS has access to KSeF (national e-invoicing system) data. If a company pays a board member a fixed remuneration without a resolution, ZUS now sees it automatically and applies the contribution with a 20% penalty on the underpayment. Previously this required a separate enforcement procedure — now it's automated.
Practical advice: if you're the sole shareholder and director of your Sp. z o.o., in 2026 you must execute a resolution appointing yourself with a salary (even minimal — say PLN 500/month) and pay the contribution from that amount. Otherwise, you risk back-assessments going up to 5 years.
Estonian CIT — best regime in 2026
Estonian CIT remains the headline advantage for foreign-owned SMEs in Poland. The 2026 model is unchanged:
- 0% tax during the reinvestment phase
- 10% (small taxpayers) or 20% (others) only when dividends are paid out
- Health contribution — PLN 0 during reinvestment
Example for a single-shareholder Sp. z o.o. with PLN 200,000 profit, fully reinvested:
- Classic CIT: 19% × 200,000 = PLN 38,000 tax + PLN 18,000 health contribution = PLN 56,000
- Estonian CIT: PLN 0 tax + PLN 0 health contribution = PLN 0 (until dividend distribution)
Saving — PLN 56,000/year. Not "optimisation" — a fully documented regime open to any small Sp. z o.o. taxpayer with Polish shareholders or shareholders holding a residence card.
For the full Estonian CIT walkthrough, see our guide Polish tax breaks: Estonian CIT and IP Box.
What a foreign entrepreneur should do
Steps for 2026:
- JDG on 19% flat with income above PLN 240,000/year — no action. Automatic saving.
- JDG on the 12/32% scale with income up to PLN 60,000/year — consider switching to ryczałt 12% (if your activity profile fits).
- Sp. z o.o. without an appointment resolution — execute one before 31 March 2026 to avoid ZUS back-assessments.
- Profitable single-shareholder Sp. z o.o. — model Estonian CIT. Up to 80% of our clients save at least PLN 30,000/year on the switch.
Deadlines and payments
The health contribution is paid monthly via PUE ZUS by the 20th of the following month. The 2026 calculation is based on the previous year's income (for new JDGs — based on the minimum).
The annual ZUS DRA return is filed by 30 April 2027 for fiscal 2026. Overpayment — refunded. Underpayment — assessed with 0.5% monthly penalty.
Frequently asked questions
The 2026 health-contribution reform affects you directly if you run a business in Poland. The LegalWin team has guided 200+ JDG and Sp. z o.o. clients through the reform in Q1 2026. Contact us for an individual calculation of your burden and the optimal regime.
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