UC92 referred to a subcommittee. Poland’s new sanctions law could take effect as early as the beginning of 2027.
The bill on restrictive measures (UC92) has been referred to a subcommittee. The new provisions could take effect as early as the beginning of 2027, and the bill allows just 30 days between publication and entry into force. We explain the penalties for sanctions violations, which businesses should monitor the changes, and why simply checking a counterparty against sanctions lists may not be enough.
Work on the bill on restrictive measures (UC92) is clearly gathering pace. On 6 October 2026, the bill was considered jointly by the Sejm’s Administration and Internal Affairs Committee, Public Finance Committee, and Economy and Development Committee. It was referred to a subcommittee for further work.
This is an important milestone not only from a legislative perspective. If work continues at a steady pace, businesses may have relatively little time to prepare for the new framework governing liability for sanctions violations and circumvention.
UC92 is intended to streamline Poland’s system for applying EU and national restrictive measures. The government has indicated that the legislation will have a horizontal scope, covering all EU sanctions regimes—currently more than 40—as well as sanctions introduced in the future.
UC92 – where does the bill stand?
The government adopted the bill on restrictive measures on 4 August 2026, and it was submitted to the Sejm on 6 August. The first reading took place on 3 September 2026. The bill was then referred to the Administration and Internal Affairs Committee, Public Finance Committee, and Economy and Development Committee. The committees were given a deadline of 20 October 2026 to present their report.
On 6 October, the committees began their detailed consideration of the bill and decided to refer it to a subcommittee.
The 20 October deadline is particularly significant because the next scheduled sitting of the Sejm will take place on 21, 22 and 23 October 2026. This means that, if the subcommittee and committees complete their work on schedule, consideration of the bill could continue during that sitting. Further sittings are scheduled for 5–6 and 17–19 November.
This does not mean that the legislation will definitely be passed in October. However, it is currently a realistic legislative scenario.
When could UC92 enter into force?
Once work in the Sejm is complete, the legislation will have to be considered by the Senate before being submitted to the President.
If proceedings move swiftly, the main legislative process could be completed as early as November 2026. However, both the Senate and the President have their own constitutional time limits, so this timing is not guaranteed.
For businesses, the short vacatio legis period provided for in the bill is particularly important. As a general rule, the new provisions are to enter into force 30 days after publication.
Therefore, if the legislation is passed, signed and published towards the end of 2026, the new sanctions framework could become operational as early as the beginning of 2027.
This means that businesses may have only a few weeks between the final wording of the provisions becoming known and the obligation to comply with them.
What will UC92 change?
UC92 is more than another amendment concerning Poland’s sanctions list.
The bill is intended to comprehensively streamline the rules for applying EU and national restrictive measures in Poland, designate the authorities responsible for their implementation, introduce a system of inspections, and regulate liability for sanctions violations and circumvention. The government expressly states that one reason for preparing the legislation was the current fragmentation of the rules, which has made them difficult to apply, particularly for businesses.
The bill also serves to implement Directive (EU) 2024/1226, which concerns criminal offences relating to violations of EU restrictive measures. The deadline for its implementation expired on 20 May 2025.
In practice, this means shifting the focus from the simple question, “Is the counterparty on a sanctions list?” to a much broader assessment of the entire transaction.
Counterparty screening alone may not be enough
For businesses engaged in international trade, the most significant change may be the practical approach to monitoring sanctions compliance.
Sanctions risk may extend beyond a person directly named on a sanctions list. Depending on the specific sanctions regime, relevant factors may include the ownership and control of the counterparty, the classification of the goods, the product’s technical specifications, the destination country, the end user, intermediaries, and the possibility of onward re-export.
This is particularly important for manufacturers, exporters, importers, distributors, logistics companies, and businesses operating within complex international supply chains.
It may affect, among others, businesses in the automotive, electronics, machinery and equipment, chemicals, metals, and plastics sectors, as well as businesses trading in products or technologies that may be subject to sectoral export restrictions.
UC92: penalties could be substantial
One of the bill’s most important elements is a significant strengthening of the liability framework.
The bill provides, among other things, for:
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administrative fines of up to PLN 20 million for certain violations or circumvention of restrictive measures;
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liability of collective entities, with penalties ranging from PLN 10,000 to PLN 200 million, or up to 5% of revenue generated in the previous financial year;
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criminal liability for individuals, with penalties reaching 12 years’ imprisonment in the most serious cases.
The bill therefore provides for administrative, corporate, and criminal liability to operate in parallel. The maximum administrative fine of PLN 20 million and the possibility of imprisonment for up to 12 years were already highlighted during the first reading in the Sejm.
For large corporate groups, the revenue-based penalty for collective entities may be particularly significant. For businesses operating on a large scale, 5% of annual revenue could far exceed PLN 200 million, depending on how the proposed rules are ultimately applied.
Which businesses should pay particular attention to UC92?
The new law will not be a concern solely for banks or other financial institutions.
Businesses engaged in international trade may face the greatest practical exposure, particularly if they sell goods outside the European Union, use distributors and intermediaries, have customers or suppliers in third countries, or trade in products subject to sectoral restrictions.
The position of businesses operating in Poland as part of foreign corporate groups will also be important. A global sanctions compliance policy does not necessarily mean that all requirements arising from Poland’s sanctions enforcement framework have been properly addressed.
What about foreign companies registered for VAT in Poland?
This issue may be particularly important in practice.
A foreign business’s VAT registration in Poland does not, in itself, automatically mean that all of its activities will be subject to Polish sanctions rules. However, it may be an important indication that the business carries out transactions connected with Poland.
If a foreign entity carries out imports, domestic supplies, stock movements, or other activities forming part of its business operations in Poland, it is worth establishing how those transactions will fall within the inspection and liability framework once UC92 enters into force.
This is particularly important for non-EU entities. EU restrictive measures may also apply to business conducted wholly or partly within the territory of the European Union.
What can businesses do before UC92 enters into force?
At this stage, the task is not yet to adapt procedures to the final wording of the law. The provisions may still be amended by the subcommittee, the committees, the Sejm, and the Senate.
However, businesses can already check whether their existing compliance systems genuinely cover the entire transaction process.
For businesses engaged in international trade, it will be particularly important to combine counterparty screening with product classification, an assessment of the destination country, end-user verification, and an assessment of re-export risk. Documenting how that verification was carried out may be equally important.
In practice, UC92 may turn sanctions compliance from a formal counterparty check before the start of a business relationship into an integral part of sales, purchasing, logistics, tariff classification, and export controls.
UC92 – what happens next?
The next key date is 20 October 2026, the deadline for the committees to present their report.
If that deadline is met, the next important milestone could be the Sejm sitting scheduled for 21–23 October. The bill will then have to pass through the Senate and the presidential stage.
The period around the end of October and the beginning of November will therefore be crucial for assessing the final scope of businesses’ obligations.
At the same time, the 30-day period between publication and entry into force means that businesses should not assume they will have several months to adapt.
If the legislative process is completed in 2026, UC92 could become one of the most significant new compliance requirements for businesses as early as the beginning of 2027.
UC92 – frequently asked questions
What is UC92?
UC92 is the reference number of the bill on restrictive measures. The bill is intended to comprehensively regulate the application of EU and national sanctions in Poland and the rules governing liability for violations and circumvention.
What stage has UC92 reached?
On 6 October 2026, the bill was considered by three Sejm committees and referred to a subcommittee for further work. The deadline for the committees’ report has been set for 20 October 2026.
When could UC92 enter into force?
No definite date can yet be given. If the parliamentary and presidential stages are completed by the end of 2026, the proposed 30-day vacatio legis period means that the main provisions could take effect at the beginning of 2027.
What penalties does UC92 provide for?
The bill provides, among other things, for administrative fines of up to PLN 20 million, liability of collective entities with penalties reaching PLN 200 million or 5% of revenue, and criminal liability for individuals, with imprisonment for up to 12 years in the most serious cases.
Does UC92 concern only businesses trading with Russia?
No. The bill has a horizontal scope and covers all EU restrictive measures regimes, not just sanctions relating to Russia. According to the government, this currently means more than 40 sanctions regimes, as well as those adopted in the future.
Contact:
Krzysztof Wiński
Partner, Thedy & Partners
tel. 519 506 434
Tomasz Orłowski
Senior Manager
tel: +48 519 504 890