In general, according to Polish law, above the 20 000 PLN threshold the sales to private individuals must be recorded by fiscal cash registers.
However, according to the Regulation of the Minister of Finance of 17 December 2024 on exemptions from the obligation to keep sales records using cash registers/Rozporządzenie Ministra Finansów z dnia 17.12.2024 r. w sprawie zwolnień z obowiązku prowadzenia ewidencji sprzedaży przy zastosowaniu kas rejestrujących
there are transactions exempt from the obligation to keep records in cash registers.
These are, among the others, delivery of goods in the shipping system (by post or courier), if the supplier of the goods receives payment in full for the activity performed by post, bank or cooperative savings and credit union (respectively to the taxpayer’s bank account or to the taxpayer’s account in the cooperative savings and credit union of which he is a member), and the records and evidence documenting the payment clearly indicate what specific activity it concerned and on whose behalf it was performed (buyer’s details, including his address).
So it is relatively easy to avoid the cash registers by receiving all payments by bank and keep register for these sales.
In case of non-PL taxpayers the situation is even more convenient. Even if such non-PL seller does not have receive all payments through bank, there are several tax interpretation/rulings saying that taxpayers not having PE/FE in Poland are not obliged to have cash registers and keep evidence of sales using cash registers e.g. 1462-IPPP3.4512.872.2016.1.RM, IPPP2/443-1271/13-5/DG
Extract from one of the rulings :
Therefore, taking into account the presented circumstances of the case, it should be stated that due to the lack of a registered office and permanent place of business in the territory of Poland, the Applicant is not obliged to record turnover and amounts of tax due using a cash register made to individuals not conducting business. The above applies to deliveries made to individuals not conducting business, both those located and residing in the territory of the country, in other Member States of the European Union as well as outside the territory of the European Union.
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