Invoice without a registered business in Poland (2026): when you can issue one

Can you invoice a company in Poland without registering a JDG? Learn how unregistered activity, receipts, NIP, VAT, KSeF and PIT work in 2026.

A person without registered JDG may issue an invoice in certain situations. Most often, this applies to unregistered activities. This does not mean, however, that every private payment can be described with an invoice or that the document itself solves the tax issue.

First, you need to determine what the payment is from: the sale of a private item, a civil law contract or an organized gainful activity. Only then do you choose the document and the settlement method.

Can an individual issue an invoice to a company?

Yes, if it sells goods or services as part of an unregistered activity and meets the conditions for this form. At the customer's request, it issues an invoice and, in the cases specified in the regulations, also an invoice.

A one-off sale of your own used item is different. This is usually a private sale documented by a contract or confirmation of payment, not a commercial invoice. Yet another case is a contract of mandate or a contract for specific work, in which the parties settle the remuneration in accordance with the contract, and the payer may have obligations regarding the advance payment PIT and tax information.

Simply calling a document an "invoice" does not change the nature of the transaction.

Unregistered activity in 2026

From 2026, the limit on unregistered activity is checked quarterly. The income due in a quarter cannot exceed 225% of the minimum wage. With the minimum wage of PLN 4,806, this gives PLN 10,813.50 per quarter.

You must also meet other conditions, including not having run a business activity in the last 60 months and not conducting any activity that requires a license, permit or entry in the register of regulated activities.

Once the limit is exceeded, the activity becomes an economic activity from the date of exceeding. You then have 7 days to submit an application to CEIDG.

More conditions and the method of calculating income are described in the guide unregistered activities in 2026.

Bill or invoice?

In the case of unregistered activity, the buyer may request an invoice. It should indicate at least the sequential number, date, details of the parties, name of the service or product and the amount to be paid.

A person benefiting from the VAT exemption does not have to issue an invoice for each sale. However, it must do so at the customer's request submitted within three months from the end of the month in which the service was performed, the goods were issued or the payment was received.

The invoice should describe the actual transaction. Do not enter VAT if you benefit from the exemption and do not settle this tax as an active taxpayer. In such a case, the document contains data relevant to the invoice of the exempt taxpayer.

Do I need NIP on my invoice?

PESEL is not an ordinary element of an invoice. In the case of unregistered sales outside KSeF, the seller uses the data required for a given document; identifiers should not be added "in spare".

NIP becomes necessary when the issuer is to use KSeF. The B2B invoice in KSeF must also correctly identify the buyer. If you plan to sell regularly to companies, it is worth organizing NIP and access to the system before the first invoice, and not after the client rejects the document.

Invoice without JDG and KSeF

KSeF is not associated solely with an entry in CEIDG. The status of the issuer in terms of VAT and the type of transaction are important. The Ministry of Finance indicates that a person running an unregistered business may be subject to the obligation to issue B2B invoices in KSeF.

A temporary simplification is in force until the end of 2026: B2B invoices can be issued outside KSeF if the total value of sales documented by such invoices does not exceed PLN 10,000 gross per month. The limit applies to the taxpayer, not to a single invoice.

Consumer invoices can be issued voluntarily at KSeF. If the issuer chooses the system, it must provide the client with access to the document in the manner prescribed by law.

VAT for unregistered activities

The absence of an entry in CEIDG does not automatically mean the absence of VAT. For the purposes of this tax, what counts is independent running of a business activity within the meaning of the Act on VAT.

Many small businesses benefit from a personal exemption up to PLN 240,000 in sales per year in 2026. However, there are activities that are excluded from the exemption, and some foreign services require VAT-UE registration. Therefore, VAT status must be determined based on what you are actually selling and to whom.

How to settle revenue in PIT?

Revenues from unregistered activities are generally settled in PIT-36 as revenues from other sources. Tax is not calculated on each issued invoice separately. The annual return shows revenue, documentable costs and income.

It is worth keeping simple sales records and keeping evidence of costs. During the inspection, what matters is the course of the transaction, not just the PDF file called the invoice.

When should you wear JDG?

Registration is required when the limit of unregistered activity is exceeded or when the activity does not meet the other conditions. Early registration may make sense if your client requires regular invoices in KSeF, you need VAT-UE, you have higher costs or you want to structure permanent contracts.

Before you decide, check:

whether sales are regular and organized,
what revenue is due in the quarter,
whether a given activity can benefit from the VAT exemption,
whether the client is a company in Poland, a foreign company or a consumer,
Do you need KSeF or VAT-UE,
what costs do you want to settle.

Frequently asked questions

Can a company post an invoice from a person without JDG?

Maybe, if the document confirms an actual transaction and contains the data required for a given type of invoice. The buyer should also check whether the settlement method corresponds to the legal relationship between the parties.

Can I issue an invoice without NIP?

In some transactions, apart from KSeF, the exempt person's document may not require a NIP issuer. In KSeF, NIP is necessary. It should not be replaced with a PESEL number.

Is unregistered activity always exempt from VAT?

NO. The exemption depends on the value and type of sale. Some goods and services exclude the exemption regardless of low turnover.

Does an invoice mean that I have to pay ZUS?

Not the invoice itself. Obligations towards ZUS depend on the basis for performing the work and whether the activity still meets the conditions for unregistered activity.

Sources

Are you reaching your limit or starting to sell to companies?

Oxyok helps you switch from unregistered activity to JDG and set up invoices, VAT, KSeF and settlements from the first month. See accounting JDG or write to [email protected].

The material is of a general nature. The appropriate document and method of taxation depend on the actual transaction and the status of the parties.