Poland has signed into law legislation implementing two EU tax transparency directives — DAC8, which introduces mandatory reporting obligations for crypto-asset service providers to combat evasion and fraud, and DAC9, which streamlines the filing of top-up tax returns for multinational groups by allowing centralised submission through a single entity.
Poland’s Ministry of Finance announced, on 11 March 2026, that the Act on the Exchange of Tax Information with Other Countries and Certain Other Acts has been signed into law. The legislation implements Council Directive (EU) 2023/2226 (DAC8) and Council Directive (EU) 2025/872 (DAC9), strengthening the framework for international tax information exchange.
It enters into force on the day following its publication.
Poland, along with other EU Member States, is required to incorporate both directives into its legal framework by the close of 2025.
DAC8 introduces mandatory reporting and the automatic exchange of information on crypto-asset transactions to strengthen the fight against tax evasion and fraud. This directive introduces new reporting and due diligence obligations for crypto-asset service providers. The European DAC8 Directive aims to increase transparency regarding crypto asset ownership, which will help combat tax avoidance and evasion more effectively. It also facilitates enhanced information exchange on cross-border rulings for high-net-worth individuals and sets penalties and compliance measures for reporting obligations. DAC8 obligations generally take effect in 2026, with the first reporting due in 2027.
DAC9 establishes a legal framework for the automatic exchange of information on equalisation taxation, enabling the centralised filing of equalisation tax returns. The new rules allow ultimate parent entities or designated filing entities of an MNE group to file the top-up tax information return under Directive (EU) 2022/2523. This removes the need for other constituent entities in different EU Member States to file separately. DAC9 also provides filing rules and a standard template for the return. As Poland implemented the Pillar Two GMT Directive late, the rules have been effective from 1 January 2025, with transitional provisions allowing application to tax years starting after 31 December 2023, consistent with the Directive.
The Act further implements provisions under Directive 2011/16/EU, including Poland’s participation in the exchange of information on cross-border tax rulings for individuals on transactions exceeding EUR 1.5 million and on income from real estate owned by non-residents.
The law, signed by the President on 9 March 2026, will take effect the day after publication in the Official Journal, while also requiring crypto-asset service providers to report transactions from the beginning of 2026 in line with DAC8.
Earlier, Poland’s Senate reviewed draft legislation to implement the EU administrative cooperation directives DAC8 and DAC9, following approval by the Senate’s Committee on Budget and Public Finance on 18 February 2026.
