The 2027 limits: the 1 October rate is published, and the office template still says 8 517 000 zł

The Number Changed on 1 October

The average NBP euro rate for 1 October 2026 (table 191/A/NBP/2026) is 4.3770 zł. A year earlier it was 4.2586 zł. Every Polish tax limit written in euro and converted "at the rate from the first working day of October of the previous year" moved with it, and this time it moved up:

Limit	In euro	2026	2027
Small taxpayer (PIT, CIT, VAT)	2 000 000	8 517 000 zł	8 754 000 zł
Lump-sum tax (ryczałt) eligibility	2 000 000	8 517 200 zł	8 754 000 zł
Lump-sum paid quarterly	200 000	851 720 zł	875 400 zł
KPiR vs full accounting books	2 500 000	10 646 500 zł	10 942 500 zł
One-off depreciation for small taxpayers	50 000	213 000 zł	219 000 zł

That's 237 000 zł more headroom under the 2 million euro limits and 296 000 zł more under the full-books threshold. Not a lot. But the clients it matters for are exactly the ones an office worries about in December, and the template most offices use to check them still says 8 517 000 zł, because that's the number everyone typed in last October.

So which number do you use for 2027? The 2027 status is decided by 2026 revenue measured against the 2027 amounts above. Ten months of 2026 revenue are already in the books. The test can be run now, not in January.

Three Clients the Rate Actually Moves

Most of an office's clients are nowhere near these limits, and the rate changes nothing for them. The ones it changes fall into three groups.

The client between the two numbers. A limited company with gross sales of 8.6 million zł in 2026. Measured against last year's figure, it has outgrown small-taxpayer status. Measured against the correct 2027 figure, it keeps it, together with the 9% CIT question, quarterly advance payments and one-off depreciation. If somebody told this client in September "you're losing the status next year", that advice now needs correcting.

The lump-sum client at 90%. A sole trader on ryczałt with 7.9 million zł of revenue by the end of September. A strong fourth quarter could take the year past 8 754 000 zł, and then ryczałt is closed for 2027 and the client moves to the general rules or the flat 19% from January. That decision isn't automatic. If the client prefers to stay on ryczałt, some of that revenue may still be planned, and November is the latest it's worth a conversation.

The KPiR client approaching full books. A general partnership of two individuals with 10.4 million zł of net sales in the first nine months. If the year closes above 10 942 500 zł, the partnership keeps full books from 1 January 2027: opening balance, accounting policy, chart of accounts, a different monthly workload and a different price. Every office I know would rather find out in October than on 10 January.

One Limit, Three Different Revenues

The trap is that "2 million euro" looks like one limit, and it isn't. Each act measures something different:

• Small taxpayer status counts sales revenue including VAT.
• Ryczałt eligibility counts business revenue, without VAT.
• Full books count net revenue from sales of goods, products and financial operations.

Take a company selling 8.2 million zł net, mostly at 23% VAT. Its gross sales are about 10 million zł. For the small-taxpayer test, it's over the limit by more than a million. A lump-sum client with the same net revenue would sit comfortably under its ryczałt limit. The same client file, two opposite answers, and a spreadsheet with one "revenue" column gets at least one of them wrong.

The 9% CIT rate adds a third layer. A company needs the small-taxpayer status (previous year, gross) and, separately, its revenue in the current year has to stay under 2 million euro. The commonly cited reading converts that current-year test at the rate from the first working day of the tax year itself, so the 2027 amount for that test doesn't exist yet. I wouldn't print a złoty figure for it until January, and I'd be suspicious of anyone who already has.

The Size of the Job

A typical office of the kind I work with: around 120 clients, of which maybe 25 on full books, 60 on KPiR and 35 on ryczałt. Under any of the limits, perhaps 6 to 10 of them are within 15% of a threshold. That's the whole population the rate change touches.

Checking one of them properly takes 20–30 minutes: pull nine months of sales, separate VAT, remove what doesn't count (fixed asset sales, for example, are treated differently under different acts), project the fourth quarter from last year's pattern, and compare with three different limits. Across the office, that's a morning. The problem has never been the time. It's that the check happens in January, after the year is closed and nothing can be planned any more.

Three mistakes come back every year:

• Last year's limit in the template. The 8 517 000 zł cell survives into the 2027 check, and the client between the two numbers gets the wrong answer.
• Gross vs net. The ryczałt and full-books tests are run on gross sales from the VAT register, which makes clients look larger than they are, or the small-taxpayer test is run on net sales, which makes them look smaller.
• Run in January. The test is correct, and too late to matter. The client learns on 15 January that they've been on full books for two weeks.

What the Agent Prepares

An agent working on the client's VAT registers and KSeF invoices and the revenue columns of the KPiR or the ryczałt register can do the assembly in November:

• Takes the 2027 amounts from the source. It reads the 1 October rate from the NBP API and calculates each limit, so nobody copies a number from an article (including this one).
• Calculates three revenue bases per client from January to the last closed month: gross sales for the small-taxpayer test, business revenue for ryczałt, and net sales of goods, products and financial operations for the full-books test.
• Projects the full year from the last twelve months, not by multiplying nine months by 4/3, because a client with a strong December is exactly the one at risk.
• Sorts clients into three groups: clearly under, in a buffer zone (say within 10% of a limit), and over. Separately, it lists clients whose status in 2027 is different from 2026, in either direction.
• Writes one line of reasoning per flagged client: which limit, which revenue base, what the projection assumes.

It doesn't tell a client to postpone invoices, doesn't change anyone's form of taxation and doesn't decide whether a projection is realistic. Only the client knows whether that big December order is real. Those are conversations for the accountant, and the agent's job is to make sure they happen in November rather than January. It fits into the month-end close the office already runs, and the small-taxpayer flag is the same one the deferred tax rate question depends on.

One Thing to Do This Week

Open the template your office uses for year-end limit checks and replace the 2026 amounts with the 2027 ones: 8 754 000 zł, 875 400 zł, 10 942 500 zł. Then check whether it has one revenue column or three. If it has one, it's giving at least some clients the wrong answer.

If you'd like to see the November list built on your own clients' data, write to me. I'll run it on one month of real registers and show you which clients land in the buffer zone and why.