MDR

We would like to inform you that on 19 June 2026, the President signed an amendment to the Tax Ordinance Act, which introduces (among others) long-awaited and significant changes to the regulations on reporting tax schemes (MDR). Currently, the amendment is awaiting publication in the Journal of Laws [edit: amendment published in Dz.U.2026.846 as of 2026.06.25]. The key provisions of the Act will enter into force on 1 October 2026, m.in those relating to tax schemes. At the same time, transitional provisions are provided for – if the deadline for the execution of the obligation related to the MDR falls on 30 October 2026, the existing regulations, i.e. the more restrictive ones, should be applicable. Below, in points 1 and 2, we present the scope of the most important changes in the regulations concerning the MDR and the Fiscal Penal Code (FPC), and in point 3 the actions we recommend. It is not worth assessing the needs and obligations individually and then adjusting them to the specifics of a particular taxpayer. The most important changes in the scope of MDR regulations Key changes include, among others: Changes to the Fiscal Penal Code (FPC) in connection with the MDR The previous provisions of the FPC provided for liability for failure to submit or untimely submission of MDR information (with the exception of MDR-3). From 1 October 2026, the sanctions will cover all types of MDR information while maintaining the current level of threat. The highest fine, i.e. up to 720 daily rates, may be imposed for the indicated violations (currently the maximum fine is over PLN 46 million, in practice the penalties imposed are lower, but still very severe). Please note that criminal liability resulting from the FPC may apply to both: Recommended actions to take in the near future ********* If you have any questions or doubts regarding the application of the current MDR regulations or the obligations arising from the new regulations, please contact us. We will be happy to help you analyze your situation and determine the right course of action. Authors: Agnieszka Czarnecka / Klara Pytel