PKD changes from 1 January 2027 – new codes, deadlines and implications for businesses

From 1 January 2027, PKD 2007 codes will be automatically converted to PKD 2025 for businesses that have not updated their registration details beforehand. The two-year transition period provided for in the legislation introducing the new Polish Classification of Activities expires at the end of 2026. Although the change primarily concerns registration records, its implications may extend beyond updating entries in CEIDG and KRS. Businesses benefiting from tax relief, preferential energy schemes and state aid mechanisms should pay particular attention.

PKD changes from 1 January 2027 – what is changing?

The Polish Classification of Activities 2025 (PKD 2025) has been in force since 1 January 2025, replacing the previous PKD 2007 classification.

The new classification has been aligned with changes to the European NACE classification and current economic realities, including the development of new technologies, the digital economy and new business models.

However, businesses operating before PKD 2025 came into force were permitted to continue using their existing codes during a transition period.

This period ends on 31 December 2026. From 1 January 2027, activities that have not previously been brought into line with PKD 2025 are scheduled to be reclassified automatically.

The changes primarily affect data recorded in:

• the Central Register and Information on Economic Activity (CEIDG);

• the National Court Register (KRS);

• the National Official Business Register (REGON);

• other official registers and systems that use the PKD classification.

It should be emphasised that PKD 2025 itself is not a new classification taking effect in 2027. It has been in force since the beginning of 2025. What will change is the position of businesses that continue to use the previous codes.

Is the PKD change in 2027 mandatory?

Yes. Businesses’ activities should be classified in accordance with PKD 2025. However, this does not mean that every business must independently submit an application to amend its registration entry by 31 December 2026.

An automatic code reclassification mechanism is envisaged for entities that do not update their details.

In practice, however, this may not always be the most suitable solution.

Some existing PKD 2007 codes correspond to several different PKD 2025 codes. In such cases, the automatic assignment of a new code may not fully reflect the activities actually carried out.

Businesses should therefore distinguish between two issues:

• formally bringing their activity codes into line with PKD 2025;

• ensuring that a particular code is correctly assigned to the activities actually performed.

The latter may be considerably more important for industrial, manufacturing and diversified businesses.

What happens if a company does not change its PKD code by the end of 2026?

If a business does not update its codes itself, its activities are scheduled to be reclassified automatically from 1 January 2027 using correspondence tables prepared by Statistics Poland (GUS).

These tables show the relationships between existing PKD 2007 codes and the new PKD 2025 codes.

For some types of activity, the transition to the new classification is relatively straightforward. An existing code corresponds to a single new code whose scope remains broadly similar.

However, problems may arise where a single PKD 2007 code has been split into several more specific types of activity.

GUS points out that, in such cases, the mapping adopted for automatic reclassification may result in the assignment of a code that does not accurately describe the business’s activities.

This means that an automatic PKD change does not guarantee that an individual company’s activities will be classified correctly.

Businesses whose existing codes have more than one equivalent under PKD 2025 should therefore consider reviewing them before the transition period ends.

How can you identify the correct PKD 2025 code?

When determining the appropriate PKD 2025 code, the first step is to verify the actual nature of the business activities carried out.

The existing PKD 2007 code and the corresponding categories in the new classification can serve as a starting point.

However, the analysis should not be limited to comparing code numbers.

For example, a manufacturing business may carry out several activities simultaneously:

• manufacturing specific products;

• processing materials;

• wholesaling products;

• providing logistics or warehousing services;

• conducting research and development.

Individual activities may fall under separate classifications, and assigning them correctly requires consideration of their actual nature.

Identifying the principal activity is also important.

For industrial businesses, it is worth reviewing not only the classification of the company as a whole, but also the specific activities of individual production plants.

How can PKD codes be changed in CEIDG and KRS?

The update procedure depends on the business’s legal form and the register in which its activity details are recorded.

Changing PKD codes in CEIDG

Sole traders update their PKD codes by amending their CEIDG entry.

When registration details are updated, the system requires activity codes to be brought into line with PKD 2025.

Attention should also be paid to codes assigned to additional places of business, where these are included in the entry.

Changing PKD codes in KRS

Companies entered in KRS amend their registered business activities through the applicable registration procedure.

If a company submits an application to change its PKD entry, it should use the PKD 2025 classification.

It is also worth checking whether the proposed change requires amendments to corporate documents, particularly the company’s articles of association or statutes.

The need to move to new PKD codes does not automatically mean that the articles of association must be amended in every case. The wording of the documents and the scope of the proposed change to the company’s business activities are relevant.

PKD 2025, tax relief and preferential energy schemes

One of the less obvious consequences of introducing the new classification is the need to assess its significance for regulations under which the type of activity carried out affects eligibility for certain benefits.

This is particularly relevant to energy-intensive businesses.

PKD codes and their corresponding NACE codes may be relevant when determining businesses’ eligibility for support mechanisms, exemptions and preferential arrangements available to specific economic sectors.

Examples include regulations concerning industrial electricity consumers and certain forms of state aid.

In such cases, carrying out manufacturing activities alone may not be sufficient to qualify for preferential treatment.

Relevant factors may include classification within an appropriate activity category, compliance with conditions relating to energy consumption, cost or revenue structure, and additional statutory requirements.

It should be emphasised that the transition from PKD 2007 to PKD 2025 does not, in itself, result in the loss or acquisition of entitlement to relief.

In each case, it is necessary to establish which version of the classification the relevant regulation refers to and what substantive conditions it sets out.

Excise duty exemption for energy-intensive establishments

Article 31d of the Excise Duty Act is an example of a provision under which the type of activity carried out is particularly important.

This provision provides for an excise duty exemption relating to electricity used by energy-intensive establishments carrying out business activities specified in the statutory list.

That list is structured by reference to designated types of business activity.

Consequently, when assessing eligibility for the exemption, it is necessary to establish not only the business’s current PKD code, but also the actual nature of its activities and the appropriate classification under the excise duty legislation.

A new PKD 2025 code recorded in KRS or REGON cannot automatically replace an analysis of the conditions for exemption under Article 31d of the Excise Duty Act.

This is particularly important where tax legislation and the current statistical classification use different activity codes.

PKD and industrial consumer status

A similar issue arises in the case of preferential mechanisms available to industrial electricity consumers.

Renewable energy legislation sets out the conditions for obtaining industrial consumer status, referring, among other things, to the type of activity carried out.

Businesses should therefore verify whether their new PKD codes correspond to the activities relevant to eligibility for preferential treatment and whether the documentation used to demonstrate entitlement remains consistent with current registration details.

Entities with several production plants or activities involving different technological processes should pay particular attention.

PKD 2025 and NACE – why does the change matter for state aid?

The new Polish Classification of Activities was developed in connection with changes to the EU’s NACE classification.

This is particularly important for state aid instruments aimed at businesses in specific industrial sectors.

Under some mechanisms, eligibility for support is determined on the basis of activities specified in annexes to EU or national regulations.

Changes to the classification structure may therefore require a review of how existing activities are mapped to the new list of sectors.

One example is the proposed electricity cost support mechanism for energy-intensive businesses, which was being developed in 2026 under legislative proposal UD459.

The proposal refers to specific types of activity listed in PKD 2025. The list of activities eligible for support was modified during the legislative process.

However, an increase in the number of PKD codes listed does not necessarily mean that the number of eligible sectors has actually expanded. Some changes may result from existing categories being divided into more detailed groupings.

For businesses, this means distinguishing between two issues: a change in the statistical code and an actual change in the scope of activities covered by a particular aid mechanism.

In practice, correctly mapping activities to PKD 2025 and NACE may have financial implications, particularly in energy-intensive sectors.

Does the PKD change affect environmental obligations?

The change in classification may also provide an opportunity to review a business’s environmental and regulatory obligations.

However, an important distinction must be maintained in this area.

Many obligations arising under regulations on waste management, packaging, chemicals or products depend primarily on the activities actually performed and the types of goods manufactured or placed on the market.

A PKD code alone therefore does not determine whether a business must register in BDO, comply with the Packaging and Packaging Waste Regulation (PPWR), or apply REACH requirements.

It may, however, be one of the elements used to identify an entity’s activities and assess its regulatory position.

For this reason, updating PKD codes may be an appropriate time to check whether registration details are consistent with the business’s actual operating profile.

Which companies should examine the PKD change particularly closely?

Although the classification change affects businesses across many sectors of the economy, its practical significance may be particularly substantial for entities engaged in complex manufacturing activities.

These include businesses in the chemical, metallurgical, automotive, food, paper, glass and ceramics industries, as well as manufacturers of plastic and rubber products.

The position of companies carrying out several different types of business activity is also relevant.

In such cases, the existing assignment to a particular PKD code may not fully reflect the scope of the activities actually performed.

Particular attention should be paid by businesses that:

• benefit from preferential energy schemes or excise duty exemptions;

• apply for state aid dependent on belonging to a particular sector;

• operate across several plants or industries;

• have existing PKD 2007 codes that correspond to several PKD 2025 codes;

• use PKD or NACE codes in regulatory and reporting documentation.

What should businesses do before 31 December 2026?

To prepare for the PKD change, businesses are advised to take several basic steps.

First – review existing PKD 2007 codes. Establish which codes reflect the activities actually carried out and which may be outdated or too broad.

Second – map activities to PKD 2025. Particular attention should be paid to cases where an existing code corresponds to several new codes.

Third – check the principal activity. For businesses carrying out different types of activity, it is important to verify that the classification adopted is correct.

Fourth – analyse the regulatory implications. Establish whether PKD or NACE codes are relevant to the tax relief, exemptions, preferential energy schemes or state aid mechanisms used by the business.

Fifth – update records and documentation. Where necessary, registration entries and internal and reporting documents should be brought up to date.

This approach can help businesses avoid discovering only after automatic reclassification that the assigned code does not reflect their actual operating profile.

Frequently asked questions – PKD changes in 2027

Will all companies have to change their PKD codes from 1 January 2027?

Businesses that still use PKD 2007 will be covered by the automatic reclassification mechanism to PKD 2025. Companies that have already correctly updated their codes will not need to change them again solely because 2027 has begun.

Do businesses have to update their PKD codes themselves by 31 December 2026?

Not in every case. Automatic reclassification is envisaged for codes that have not already been updated. However, an independent review is particularly advisable where an existing code corresponds to several new types of activity.

Will GUS automatically change PKD codes in 2027?

Yes. According to information from GUS, activities that remain classified under PKD 2007 are scheduled to be reclassified automatically from 1 January 2027, using the correspondence tables that have been prepared.

Does changing PKD codes require amendments to the articles of association?

Not always. Whether the articles of association need to be amended depends on their existing wording and the scope of changes to the company’s business activities. A technical update of codes should be distinguished from a substantive change in the company’s activities.

Can the PKD change result in the loss of tax relief?

A change in the statistical code alone should not automatically result in the loss of tax entitlements. However, where a regulation refers to specific activity codes, the relevant provisions and the actual conditions for applying the preferential treatment must be checked.

Is PKD 2025 relevant to industrial consumers?

Yes. The type of activity carried out is one of the factors relevant to certain support mechanisms and preferential energy schemes. The new classification therefore requires businesses to check that their activity codes are consistent with the relevant regulations.

What should a business do if the automatically assigned PKD code is incorrect?

The business should verify the actual scope of its activities and make the appropriate amendment in the relevant register. In more complex cases, an analysis of the classification rules and PKD correspondence tables may be helpful.

Summary – the PKD change is more than a formality

The end of the transition period associated with the introduction of PKD 2025 is particularly relevant to businesses that continue to use the previous classification.

Automatic reclassification of activities is envisaged from 1 January 2027, but this mechanism will not always ensure that the code assigned best reflects the business’s actual activities.

This is particularly significant for manufacturing and energy-intensive businesses, for which activity classification may be an important factor in determining entitlement to tax relief, preferential energy schemes and state aid mechanisms.

Before the end of 2026, it is therefore worth reviewing not only the accuracy of PKD codes, but also their relationship with regulations relevant to the business’s operations.

How can we help?

At Thedy & Partners, we support businesses in analysing PKD and NACE classifications and assessing the significance of these codes for regulatory obligations and eligibility for preferential treatment.

In particular, we help verify:

• whether activities have been correctly mapped to PKD 2025;

• whether the new codes accurately reflect the processes actually carried out;

Contact:

Krzysztof Wiński
Partner, Thedy & Partners
krzysztof.winski@thedy.pl
+48 519 506 434

Łukasz Pamuła
Senior Manager, Thedy & Partners
lukasz.pamula@thedy.pl
+48 519 504 779