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August 2, 2026
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October 14, 2026Virtual cash register service from 2028 – what does the amendment to the VAT Act change?
The virtual cash register service has not yet had its own, detailed regulations. This type of cash register operates as an application, not a device with a seal that periodically visits a service technician. This is set to change on January 1, 2028: the Minister of Finance will be given a framework to define the virtual cash register service and the requirements that companies providing it must meet. In this article, we explain what is already known, what we are still waiting for, and what is worth checking out now.
Virtual cash register in a nutshell
A virtual cash register is a software-based cash register. You install it on your smartphone, tablet, or computer, and sales data is transferred to the Central Cash Register Repository, a system run by the Ministry of Finance. Virtual cash registers have been operating in Poland since June 2020.
Importantly, not every company can use virtual cash registers. Regulations only allow them in specific industries, including passenger transport, catering, accommodation services, and car washes. As of April 1, 2026, the catalog has been expanded to include vending machines and electronic parking systems, among others. Details can be found in the article about whether you meet the requirements for using a virtual cash register.
What does a virtual cash register service look like today?
A virtual cash register service is completely different from a hardware cash register service. The in-app cash register has no casing, seals, or replaceable fiscal memory, which are monitored by a service technician. In practice, the software provider is responsible for the program's operation, updates, and user support.
The technical requirements for virtual cash registers and the rules for their use are currently defined in the regulation of the Minister of Finance of June 25, 2025, regarding software-based cash registers. However, the service regulations have been tailored primarily to the devices. Therefore, app-based cash registers require separate, precise rules – and this amendment paves the way for these.
What does the Act of 4 September 2026 change?
The amendment to the Act expands the authority of the Minister of Public Finance. The Minister will be able to define in a regulation the conditions for organizing and operating software-based cash register services. The regulation also specifies requirements for entities that provide such services. The amendment comes into force on January 1, 2028. It is based on the Act of September 4, 2026, amending the Act on Goods and Services Tax and the Act on the Principles of Recording and Identification of Taxpayers and Payers (Journal of Laws of 2026, item 1270).
What does this mean in practice?
A new regulation on virtual cash registers or a change to the current one is expected. Until then, the current rules will remain in effect, so there's no need to change anything today.
What are we waiting for – questions that the regulation will answer
The law specifies what the regulation will cover, but it doesn't specify the details. So, instead of guessing, we've compiled the questions we hear most frequently from clients. We'll have the answers when the draft regulation is released, and we'll update this article at that time.
| What we already know | What are we waiting for? |
|---|---|
| The Minister of Finance will determine the conditions for organizing and operating the virtual cash register service. | Who exactly will be able to provide the service and what requirements will they have to meet? |
| The regulation will define requirements for service providers. | Will there be periodic activities, similar to inspections of hardware cash registers? |
| The legal basis is effective from 1 January 2028. | How to document service and will it change supplier contracts? |
| The change only applies to software cash registers. | Is there a transition period for existing users? |
Do you use a virtual cash register? What's worth checking out now?
Although we will only learn about the new rules of the service, there are a few things worth sorting out today.
- Check if your business is still listed. Virtual cash registers can only be used in industries specified in the regulations.
- Read the provider's contract or terms and conditions. Find out who is responsible for technical support and updates, and how quickly they respond to requests.
- Prepare a plan B for emergencies. Consider what you'll do if your phone, tablet, or internet connection fails. Ask your provider for the recommended procedure.
- Remember the cancellation policy. If you stop using a virtual cash register, issue a fiscal settlement report and submit a deregistration request within 5 days. As of January 1, 2027, late registration will incur a PLN 300 fine – for more useful information, see our article on deregistering a cash register.
Virtual cash register or online cash register – do new regulations change the bill?
Not currently. The amendment does not impose new obligations on virtual cash register users before 2028. However, it is worth considering that the rules for the virtual cash register service are still being developed, and the costs and requirements will be known later.
If you're still choosing a solution, compare both options. The article "Online Cash Register vs. Virtual Cash Register" may be helpful. The article "Virtual Cash Register vs. POS System" is also worth reading. If your industry isn't listed in the virtual cash register directory, consider purchasing an online cash register or a fiscal printer compatible with your point-of-sale system.
Cash registers 2027–2028 – what changes await us:
The virtual cash register service is the last stage of changes that await cash register users in the coming months:
- January 1, 2027 - a fine of PLN 300 will come into effect for failure to submit an application for deregistration of a cash register - including a virtual one - on time.
- On the same date, a ban on issuing invoices using cash registers will come into force.
- On July 1, 2027, a ban on replacing fiscal memory in cash registers with electronic copy recording will come into force.
- On January 1, 2028, the basis for new regulations on the virtual cash register service will come into force.
Virtual cash registers, online cash registers and IT support from the Cash Register Center
At the Cash Center, we help you choose a fiscal solution tailored to your specific industry and workflow. We offer:
- virtual cash registers for industries that can use them,
- online cash registers and fiscal printers for other companies,
- IT implementation and support – remotely or on-site,
- cash register service in Warsaw, Łódź, Tricity and throughout Poland.
