VAT 2027: Simpler Export Documentation and the End of Paper Import Declarations
14.05.2026
The Polish Ministry of Finance has presented a draft amendment to the VAT Act, scheduled to enter into force on 1 January 2027. The proposed changes implement deregulation measures and align Polish regulations with the reform of EU customs law. The amendment covers three key areas: export documentation for applying the 0% VAT rate, the digitalization of import declarations, and the IOSS-related USZ procedure. For exporters and importers, the reform introduces tangible simplifications and a new implementation timeline.
What documents will confirm exports after the changes?
Under the new rules, exporters will be allowed to apply the 0% VAT rate based not only on customs documents but also on other forms of evidence, provided that such documents reliably confirm the export of goods outside the EU. The draft incorporates the case law of the Court of Justice of the European Union (CJEU) and Polish administrative courts into statutory provisions. This change resolves a long-standing dispute between taxpayers and tax authorities.
Current regulations recognize only documents confirmed by the competent customs authority. While courts have consistently accepted alternative evidence, tax offices have generally adhered to the literal wording of the Act. The amendment broadens the catalogue of acceptable documents and protects exporters from being denied the 0% VAT rate solely because of the form of documentation used.
Exporters should review what alternative proof of export they may collect, such as carrier confirmations, destination port documents, or commercial correspondence. The draft also provides for a transitional period regarding advance payments received for exports. Further details will be refined during the legislative process.
In practice, the expanded catalogue of documents will provide greater certainty in VAT settlements. Companies supplying goods outside the EU will be able to prove export even if, for various reasons, they do not receive the IE-599 message. It will be sufficient to demonstrate the actual export in a coherent and credible manner.
What will change in import declarations?
Import declarations under centralized clearance procedures will only be submitted electronically. Paper forms will be eliminated. The amendment concerns Article 33b of the VAT Act and its implementing regulations. The greatest benefits will be seen by importers operating under customs clearance procedures involving several EU Member States.
Centralized clearance is based on cooperation between the customs administrations of at least two Member States. Currently, taxpayers submit import declarations using paper templates. Following the reform, the Ministry of Finance will adapt regulations to fully electronic document circulation.
Importers should already verify whether their accounting systems and communication channels with the administration are ready for the new standard. Early preparation will spread IT implementation costs over time and help avoid disruptions in settlements at the beginning of 2027.
How will the amendment affect the USZ procedure?
The USZ procedure allows VAT on e-commerce consignments valued up to EUR 150 imported from outside the EU to be settled collectively. The draft adapts this mechanism to new customs regulations that will enter into force on 1 July 2026. Without these changes, the procedure would cease to function, and importers would have to settle each shipment individually. The amendment preserves the simplification.
The USZ procedure is one of the key tools supporting e-commerce trade with third countries. The draft clarifies the scope of declarations submitted under this procedure, the competence of authorities, and record-keeping requirements. It also introduces mandatory electronic filing of declarations.
The provisions concerning the USZ procedure will enter into force earlier than the rest of the Act — on the day following its publication. Postal operators, courier companies, and importers of low-value consignments should therefore prepare for the changes as soon as possible.
The full digitalization of USZ declarations will streamline the settlement of thousands of shipments each month. Businesses handling cross-border e-commerce will benefit from a uniform VAT reporting standard for parcels valued up to EUR 150. Without the amendment, each shipment would have to be settled under general rules, increasing administrative costs and extending customs clearance times.
When will the new regulations come into force?
Most of the provisions are scheduled to take effect on 1 January 2027. The exception concerns the USZ procedure provisions, which will apply from the day after the publication of the Act. The Council of Ministers plans to adopt the draft in Q2 2026. Businesses will therefore have only a few months to prepare their systems.
The timeline directly results from the reform of EU customs law. The draft has been included in the legislative and policy agenda of the Council of Ministers as a deregulation initiative. Before entering into force, the amendment will still undergo public consultations, institutional reviews, and the parliamentary process.
What does the draft mean for taxpayers?
The amendment will significantly reduce tax risk in exports. Exporters concerned about being denied the 0% VAT rate due to non-standard documentation will benefit from clearer and more secure regulations. Importers will gain from digitalization and the continuity of the USZ procedure. The entire sector is expected to save time and reduce disputes with the tax administration.
From a tax perspective, two actions are particularly important. First, companies should review their export documentation policies and determine what evidence they will systematically collect. Second, businesses should audit their IT systems to ensure readiness for electronic communication with the customs and tax administration.
