Nearly One Year of Mandatory e-Delivery Addresses for Companies Registered in KRS – Still No Sanctions

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For almost a year now, companies registered in the entrepreneurs’ register of the National Court Register (KRS) have been required to hold an official e-Delivery address. This obligation forms part of a broader digital transformation of communication between businesses and public administration.

However, the legislator has not introduced direct sanctions for non-compliance. As a result, there are still companies that cannot be contacted electronically, even though they are formally required to maintain an active digital mailbox.

What does this mean for management boards, accountants and legal departments? And does the lack of penalties truly mean there is no risk?

Who Is Subject to the Obligation – and Since When?

The implementation timeline depends on the legal form of business activity.

Companies Registered in KRS

Entities entered in the entrepreneurs’ register of KRS – mainly commercial law companies – became subject to the obligation at the beginning of 2025:

• some as of 1 January 2025,

• others as of 1 April 2025.

For this group, the obligation is already fully binding.

Sole Traders Registered in CEIDG

The situation differs for entrepreneurs registered in the Central Register and Information on Economic Activity (CEIDG):

• the obligation already applies to those who started their business after 1 January 2025,

• it also applies to entrepreneurs updating their existing registration,

• all remaining CEIDG entrepreneurs will be covered as of 1 October 2026.

  
  

In practice, full inclusion of all entrepreneurs in the e-Delivery system will only be completed in the coming months.

Statistics vs. Reality – How Many Businesses Still Lack an Address?

According to data published by the Ministry of Digital Affairs, more than 1.1 million e-Delivery addresses have already been registered for entrepreneurs.

For comparison, the Statistics Poland reports approximately 734,000 commercial law companies operating in Poland.

At first glance, these figures suggest strong implementation. However:

• the statistics also include sole traders from CEIDG,

• many entrepreneurs registered voluntarily before their statutory deadline,

• the available data does not clearly indicate how many entities already subject to the obligation have failed to comply.

In other words, the system is operational, but the actual level of compliance among companies remains unclear.

Why Do Some Companies Still Lack an Active e-Delivery Address?

In practice, the reasons vary:

• lack of awareness of the obligation,

• incomplete registration (for example, activation links sent to spam folders),

• incorrect assumption that the obligation does not yet apply,

• deliberate avoidance in the belief that it limits official contact.

The last approach is particularly risky. Failing to establish an e-Delivery address does not shield a company from administrative proceedings or legal responsibility. On the contrary, it may create additional procedural complications.

No Sanctions Does Not Mean No Risk

Although there are currently no direct financial penalties for failing to establish an e-Delivery address, this should not be interpreted as permission to ignore the obligation.

Potential risks include:

• difficulties in receiving official correspondence on time,

• communication barriers with courts and administrative authorities,

• negative assessments during audits or inspections,

• reputational impact in relations with business partners.

In an era of digital administration, failure to implement e-Delivery solutions may be perceived as a lack of due diligence in corporate governance.

What Should Companies and Accounting Offices Do?

From the perspective of management boards and finance teams, it is advisable to:

1. Verify whether the e-Delivery address has been properly established and activated.

2. Ensure that registration data remains up to date.

3. Designate a responsible person to monitor the mailbox.

4. Introduce internal procedures for handling electronic correspondence.

For accounting offices and tax advisors, this area presents an opportunity to provide tangible support to clients – both in verifying compliance and in implementing appropriate internal processes.

Digitalisation Is a Process, Not a One-Off Action

The obligation to maintain an e-Delivery address is more than a technical requirement. It forms part of a broader digital transformation trend affecting public administration, including initiatives such as mandatory e-invoicing and expanded electronic court services.

The current absence of sanctions may only be temporary. Businesses should treat this period as an opportunity to organise and strengthen their compliance processes before stricter enforcement mechanisms are introduced.