Executive summary

The Polish Ministry of Digital Affairs has proposed legislation introducing a Digital Services Tax (DST), with consultations beginning on 2 February 2026.

In addition to ongoing public consultations on the DST model, the Ministry has submitted a request to include the new bill in the government's legislative agenda. The proposed tax — also referred to as the "digital tax" — would apply to groups with global revenues exceeding €1b and Polish-taxable revenues exceeding 25 million Polish zlotys (PLN25m) annually. The intended rate will not exceed 3%, reduced by corporate income tax (CIT) already paid. The draft is planned for adoption by the Council of Ministers in the second quarter of 2026.

The proposal aims to level the playing field between domestic businesses and global platforms providing services in Poland, reinforce Poland's digital sovereignty and increase budget revenues to support technological development.

Key developments

Scope of taxation

The DST would apply to revenue generated in Poland from the following categories of digital services:

• Digital advertising — placement of ads on digital interfaces such as websites or mobile applications
• Multisided digital interfaces enabling user interaction — e.g., social media platforms or similar services allowing users to interact
• Sale or paid sharing of user data — including individual and aggregated data used for analytical or marketing purposes

Thresholds

Entities or consolidated groups will be subject to the DST if their global revenues exceed €1b, and their Polish-taxable revenues exceed PLN25m annually, regardless of their tax residence or location of management. The Ministry has increased the original threshold of €750m million to €1b in the updated proposal.

Tax rate and base

The tax base will consist of revenue from the above services generated in Poland. The tax rate will not exceed 3%. The DST liability will be reduced by CIT already paid.

Exemptions

Several types of digital activities are expressly excluded from DST, including streaming services providing proprietary or licensed digital content, regulated financial services (including trading systems and payment facilitators), direct online sale of goods and services (in which the supplier operates its own online store) and internet media (in which the predominant activity is editorial content publication).

Administrative and compliance implications

Entities within the DST scope may face additional reporting obligations. Given the early stage of the legislative process, companies should monitor the developments closely.

Impact

If implemented, the DST will introduce a new tax burden for large multinational digital groups generating significant revenues in Poland. The reform seeks to equalize competitive conditions between local service providers and global digital platforms operating cross-border. It would also expand Poland's fiscal capacity to invest in technological priorities. At the same time, the proposed exemptions indicate the government's intent to limit the tax to specific digital business models, consistent with approaches seen in other jurisdictions introducing similar levies.

Next steps

The Council of Ministers is expected to review the draft legislation in the second quarter of 2026.

EY Poland will continue to monitor developments surrounding the proposed Digital Services Tax.