Polish Investment Zone: planned changes and their importance for investors in Poland

The Polish Investment Zone remains one of the most important instruments supporting new investment projects in Poland. The planned amendment to the Act on Supporting New Investments is intended to organise the system after the expiry of the special economic zones, increase the attractiveness of tax exemptions, and reduce some of the practical issues investors have faced in recent years.

The changes are particularly important for foreign entrepreneurs considering starting business activity in Poland, building a production plant, expanding existing operations, or reinvesting in an already operating facility. The Polish Investment Zone allows companies to benefit from an income tax exemption in connection with a new investment, which means it can directly affect the financial viability of a project.

At this stage, the assumptions of the draft amendment are known. The final impact of the changes will depend on the wording of the regulations, transitional provisions, and the practice of the authorities responsible for issuing and monitoring support decisions.

Why are changes to the Polish Investment Zone planned?

The Polish Investment Zone was introduced as a successor to the special economic zone model. The previous system was linked to specific zone areas. The Polish Investment Zone extended the possibility of obtaining support to the entire territory of Poland, provided that requirements relating, among other things, to the value of the investment, the project location, and qualitative criteria are met.

This model has become an important tool for attracting investment. From September 2018 to the end of 2025, a total of 3,700 support decisions were issued, covering PLN 154.4 billion in declared investment value and 55,570 new jobs. These figures show that the instrument has been actively used by both Polish and foreign entrepreneurs.

At the same time, practice has shown that some rules require clarification. The main problems concerned the settlement of tax exemptions for reinvestments, employment conditions, the expiry or revocation of support decisions, and investor service after the end of the special economic zone system.

From the perspective of a foreign entrepreneur, predictability is particularly important. An investor deciding to locate a project in Poland analyses not only the amount of potential support, but also the stability of the rules, the time needed to obtain a decision, the conditions for maintaining the relief, and the risks connected with later audits or inspections.

The end of special economic zones and the continued operation of the Polish Investment Zone

One of the main reasons for the amendment is the expiry of the special economic zone system. The existing zone-based model is expected to end at the close of 2026, and the investment support system is to be reorganised around the Act on Supporting New Investments.

This does not mean the end of support for investors. On the contrary, the planned changes are intended to ensure continuity and adapt the Polish Investment Zone to the reality after the expiry of the special economic zones.

For entrepreneurs, this means that the new rules should be monitored closely. Companies planning an investment in Poland should verify whether their project will still meet the conditions for obtaining a support decision and whether the planned changes may improve the economic rationale of the investment.

It will also be important to determine whether the new regulations will apply only to decisions issued after the amendment enters into force, or also to decisions already in effect. This may be significant for companies carrying out long-term projects or planning further stages of investment based on an existing operating structure.

Support decision – why is it important for investors?

A support decision is the key document enabling a company to benefit from a tax exemption under the Polish Investment Zone. In practice, it specifies, among other things, the type of activity covered by the support, the investment location, the conditions for implementing the project, and the period during which the entrepreneur may use the preference.

For a foreign investor, a support decision may be an important element of the financial model. The tax exemption can improve project profitability, shorten the payback period, or increase Poland’s attractiveness compared with other locations in the region.

At the same time, a support decision should not be treated merely as a formal tax relief. It is also a commitment that requires specific conditions to be met throughout the period of validity of the decision. Mistakes at the investment planning stage, an incorrect definition of the scope of activity, or underestimating the obligations may create the risk of losing the right to the exemption or having to return the aid received.

Extension of the support decision period to 20 years

One of the most important announced changes is the extension of the validity period of support decisions to 20 years for all areas. According to the draft assumptions, this solution is intended to enable entrepreneurs to use their available relief more effectively and to make the instrument more attractive.

For investors, this change may have considerable practical importance. The amount of public aid depends on eligible costs and the applicable regional aid intensity. However, the duration of the decision affects whether the entrepreneur can actually use the available exemption limit. In large investment projects, the first years after completion of the investment do not always generate high profitability. A plant may gradually increase production capacity, incur start-up costs, invest in staff, certification, suppliers, and process organisation. If the period for using the exemption is too short, part of the available aid may remain unused.

Extending support decisions to 20 years may be particularly important for:

• capital-intensive manufacturing investments,
• projects implemented in stages,
• reinvestments in existing plants,
• investments requiring a long period to reach full profitability,
• projects strongly affected by business cycles.

From the perspective of a foreign investor, this change may increase the predictability of the financial model and make it easier to compare Poland with other investment locations.

Simplifying tax exemption settlements for reinvestments

Another very important area of the planned changes concerns the rules for settling tax exemptions in the case of reinvestments. This applies to situations where a company does not build a completely new plant, but develops existing operations, increases production capacity, diversifies production, or changes the production process.

Under the current model, a significant problem has been determining what part of income is generated by the new investment and what part comes from existing activity. In practice, this has led to disputes over how to separate exempt income and how to apply the concept of close links between the new investment and previous activity.

The planned change is intended to cover all income generated by the existing set of assets with the exemption, provided that the subject of the previous activity and the activity carried out as part of the new investment are described by the same Polish Classification of Products and Services (PKWiU) code.

For entrepreneurs, this may mean a significant simplification. Many investments carried out by foreign companies in Poland are reinvestments. A business may expand a hall, install new production lines, modernise machinery, or automate processes in an existing plant. In such a model, separating income from the new investment from income generated by existing activity can be complicated.

If the new regulations genuinely simplify this mechanism, the Polish Investment Zone may become more predictable for companies already operating in Poland and considering further stages of development.

Deferring the use of the exemption until the investment is completed

The draft assumptions also provide for deferring the moment when the tax exemption can be used in reinvestment projects until the investment is completed. The aim of this solution is to make the settlement of public aid more transparent.

For investors, however, the key issue will be how precisely the moment of investment completion is defined and what tax consequences arise during the implementation period. Industrial investments are often carried out in several stages. They may include land preparation, construction work, machinery purchases, installation of technological lines, testing, technical acceptance, and gradual production launch.

If the regulations are precise, deferral may reduce settlement doubts. If, however, they leave too much room for interpretation, entrepreneurs will need to plan the investment schedule, cost documentation, and the moment of starting to use the exemption particularly carefully.

From the perspective of a foreign investor, this element is important not only from a tax perspective, but also financially. The moment when the exemption begins to apply affects cash flow, profitability forecasts, and the assessment of project viability at group level.

Opinion of the Poland’s Head of the National Revenue Administration – more certainty or a longer procedure?

One of the more significant announcements is the introduction of an obligation to obtain an opinion from the Head of the National Revenue Administration (KAS) on the amount of income exempt under a support decision. The purpose of this opinion would be to ensure correct and consistent application of the regulations on tax exemptions.

This solution may have two effects.

On the one hand, an earlier tax assessment may increase investor security. If the scope of exempt income is assessed before the decision is issued or during its preparation, the entrepreneur may gain greater certainty about how the relief should later be settled.

On the other hand, an additional opinion stage may extend the procedure. In foreign investment projects, timing is often critical. The project schedule may be linked to group management decisions, financing, land acquisition, technology delivery deadlines, or obligations towards business partners.

Therefore, the practical assessment of this change will depend on the details. It will be important to know whether the procedure for obtaining the opinion will be fast and predictable, or whether it will become an additional source of formalities. It will also matter whether the investor will have a clear path to follow in the event of a negative assessment or the need to change project parameters.

Changes to the employment condition

The planned amendment is also expected to address the employment condition, especially where eligible costs consist only of investment costs. This is important because many modern manufacturing projects are no longer primarily based on creating a large number of jobs, but on increasing efficiency, automation, and implementing advanced technologies.

Until now, employment requirements could be difficult to reconcile with the realities of modern investments. A company investing in robotisation, digitalisation, or modernisation of production lines may increase added value and plant competitiveness without a proportional increase in employment.

From the perspective of a foreign investor, clarification in this area may be highly relevant. Entrepreneurs planning an investment in Poland should know whether they will be required to create new jobs, maintain a certain employment level, or whether investment expenditure will be the main project parameter.

At this stage, it is not yet clear how far the changes will go. What matters is whether the new regulations will truly adapt support conditions to highly automated investments, or merely clarify existing obligations.

Electronic Platform of the Polish Investment Zone

The draft also provides for regulation of the Electronic Platform of the Polish Investment Zone, known as ePSI. The platform is intended to streamline and automate processes related to applying for a support decision, amending decisions, terminating decisions, and monitoring the effects of support.

For investors, this may be a positive change if digitalisation leads to a real simplification of procedures. In practice, what matters is not only the ability to submit documents electronically, but also transparency of case status, smoother communication with the relevant entities, and a reduction in requests for additional documentation.

For foreign entrepreneurs, ePSI may also have organisational importance. Centralising the process and increasing documentation transparency may make it easier to coordinate the project between the Polish company, group headquarters, advisers, the finance team, and the people responsible for the investment.

However, the success of the platform will depend on how it works in practice. Digitalisation alone will not solve problems if procedures remain unclear or processing times remain long. The key question will therefore be whether ePSI improves the actual efficiency of investor service.

The new role of area managers

After the expiry of the special economic zones, it will also be necessary to organise the role of entities responsible for investor service. The draft assumes that the regulations will be supplemented with a definition of a managing entity and a clarification of its tasks.

This is important because the existing zone managers have played a significant role in investor service. They have supported entrepreneurs in preparing applications, issuing support decisions, monitoring obligations, and amending decisions.

For a foreign investor, a clear definition of the powers of such entities has practical importance. It helps determine who should be contacted at the investment preparation stage, who is responsible for formal support, and what obligations will be performed after the support decision is issued.

The draft also provides for additional obligations for managing entities, including those related to public procurement, as well as the possibility of their involvement in projects concerning renewable energy sources and energy efficiency. This may be relevant for entrepreneurs planning industrial investments connected with the energy transition.

What do the changes mean for new investors?

For companies planning to enter the Polish market, the planned amendment may increase the attractiveness of the Polish Investment Zone. Three elements are particularly important: a longer support decision period, potentially simpler rules for settling the exemption, and greater digitalisation of procedures.

However, foreign investors should bear in mind that the draft is still at the legislative stage. This means that decisions should not be made solely on the basis of announcements. Nevertheless, it is worth analysing now whether a planned investment may qualify for support and which project structure options may be the safest.

At the planning stage, the following issues are particularly important:

• correctly defining the scope of activity covered by the support decision,
• selecting the investment location,
• determining eligible costs,
• setting the schedule for incurring expenditure,
• assessing the impact of the investment on employment,
• defining the model for settling exempt income,
• identifying risks connected with possible future changes to the project.

The earlier these issues are analysed, the easier it will be to adapt the investment to the new rules.

What do the changes mean for companies already operating in Poland?

The planned amendment may be equally important for entrepreneurs already conducting business in Poland. This applies in particular to companies that already hold a support decision or are planning reinvestment in an existing plant.

For such entities, transitional provisions will be key. They will show whether the new rules apply only to future decisions or also to decisions already issued. This is especially important in the context of extending the validity period of decisions to 20 years and simplifying the rules for settling exempt income.

Companies already operating in Poland should analyse whether the planned changes may affect:

• the use of the available public aid limit,
• the settlement of income from reinvestment,
• employment-related obligations,
• the possibility of amending a support decision,
• the schedule of subsequent investment stages,
• the risk of expiry or revocation of the decision.

In practice, the amendment may be an opportunity to reassess the investment structure and the way in which the tax exemption is used.

Risks and issues that remain open

Although the direction of the changes appears favourable for investors, some issues remain open. The most important questions concern the scope of application of the new provisions, the impact of the opinion of the Head of the National Revenue Administration (KAS) on the duration of the procedure, the detailed rules for settling the exemption, and employment conditions.

For entrepreneurs, it will also be important to know whether the new regulations will genuinely simplify the system or merely move some doubts to another stage of the procedure. For example, an opinion from the Head of the National Revenue Administration may increase tax security, but only if the procedure is clear, timely, and predictable. Similarly, ePSI may improve investor service, but its importance will depend on the quality of the system, the range of available functions, and administrative practice.

At this stage, caution is particularly important. Investors should not assume that all announcements will be adopted unchanged. Only the publication of the draft, the course of legislative work, and the transitional provisions will make it possible to assess the full consequences of the amendment.

How to prepare for the changes?

Companies interested in investing in Poland should already analyse the impact of the planned regulations on their projects. This applies both to new investors and to businesses that already have a plant in Poland and are considering expansion.

In practice, several areas deserve attention.

First, it is necessary to assess whether the planned investment may qualify for support under the Polish Investment Zone. Location, expenditure value, type of activity, and fulfilment of qualitative criteria are all relevant.

Second, it is worth preparing a financial model that takes into account a longer support decision period. If the decision is valid for 20 years, the real possibility of using the exemption may be greater than under the current model.

Third, companies planning reinvestments should analyse whether their existing activity and the activity covered by the new project can be correctly described using Polish Classification of Products and Services (PKWiU) codes. This may be important for determining the scope of income covered by the exemption.

Fourth, the potential impact of the opinion of the Head of the National Revenue Administration (KAS) on the project schedule should be taken into account. If the opinion becomes a mandatory element of the process, investors will need to plan more time for the formal stage.

Fifth, entrepreneurs should verify their employment assumptions. This applies in particular to projects based on automation, robotisation, and modernisation of production processes.

The Polish Investment Zone as part of business location decisions

For a foreign investor, the Polish Investment Zone is one element of a broader business location decision. The tax relief alone does not determine the choice of country, but it can significantly affect the final assessment of a project.

Investors also analyse workforce availability, operating costs, infrastructure, access to the European Union market, regulatory stability, administrative quality, and long-term development potential. If the planned changes increase the predictability of the Polish Investment Zone, Poland may strengthen its position as a location for manufacturing, logistics, and technology projects.

At the same time, the support system should be assessed realistically. A support decision does not eliminate tax, accounting, legal, or reporting obligations. It requires proper documentation, monitoring of conditions, and compliant settlement of public aid.

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The planned changes to the Polish Investment Zone may be significant for entrepreneurs planning business activity in Poland and for companies already carrying out investment projects here. The most important announcements concern extending the validity period of support decisions to 20 years, simplifying settlements for reinvestments, introducing an opinion from the Head of the National Revenue Administration (KAS), clarifying the employment condition, and digitalising procedures through the ePSI platform.

The direction of the changes can be seen as an attempt to increase Poland’s attractiveness for investors and organise the system after the expiry of the special economic zones. For entrepreneurs, however, the final wording of the regulations and whether the new rules will also apply to decisions already issued will be crucial. From the perspective of a foreign investor, the Polish Investment Zone remains an important instrument that may improve the profitability of a project in Poland. However, it requires careful planning, proper documentation, and ongoing monitoring of legislative changes.