New PKD classification – PKD 2025. Implications and obligations for companies: a practical guide

Why is the introduction of the new PKD classification (PKD 2025) important for businesses?

PKD (Polish Classification of Activities) codes are more than just a formal element of company registration. Accurate and up to date PKD codes, properly reflecting the company’s business activities, have practical operational significance. They may determine access to funding, eligibility to participate in tenders or grant competitions, affect the company’s assessment as a business counterparty in KYC or AML procedures, or – in certain cases – affect the right to recognise expenditure as tax deductible business expense.

As of 1 January 2025, a new PKD classification – PKD 2025 – is in force. It requires businesses (in particular companies and sole proprietors) to adjust the PKD codes disclosed in official registers. Although the regulations have provided for a transitional period ending on 31 December 2026, it is advisable to review PKD codes in advance, especially if a business plans to update any information disclosed in the National Court Register (KRS) in the near future. Failure to update PKD codes independently during the transitional period will result in their automatic reclassification in the relevant registers, which may lead to the assignment of PKD codes that do not accurately reflect the business activities actually carried out by the company.

What are PKD codes and who is obliged to use them?

The Polish Classification of Activities (PKD) is a standardised system of codes that enables, for example, public authorities, banks and business partners to quickly determine the nature of a company’s actual business activities.

The obligation to indicate PKD codes applies in particular to:

• sole proprietorships (with codes entered in the Central Register and Information on Business Activity – CEIDG),
• commercial companies, including limited liability companies and joint-stock companies (with codes entered in the National Court Register – KRS).

Importantly, PKD codes should reflect the actual business profile on an ongoing basis. Any expansion of the company’s offering, introduction of a new service or change in the business model requires consideration of whether the relevant register entry should be updated. Outdated or inappropriate PKD codes, including those that may be automatically reclassified after the end of the transitional period, i.e. after 31 December 2026, may have real consequences for a business.

Problems with financing, grants and participation in tenders or competition

Financial institutions, grant-awarding bodies and entities organising tenders and competitions routinely verify PKD codes when assessing risk, project eligibility or the credibility of participants. Discrepancies between the information recorded in CEIDG or KRS and the actual business activities, or the use of PKD codes indicated under an obsolete classification, may result in a refusal to grant financing or funding, or to allow a business to participate in a tender or competition.

Reduced business credibility

In the era of KYC and AML procedures, customers and business partners often conduct detailed checks of the nature of a company’s business activities. Inconsistencies or outdated information concerning PKD codes may, in extreme cases, result in a refusal to enter into a business relationship, the suspension of cooperation or the termination of an existing business relationship.

Tax risk and the potential disallowance of expenses

Tax authorities carefully examine whether expenditure incurred by a company has a genuine connection with its business activities. Although the absence of an appropriate PKD code does not automatically prevent an expense from being treated as a tax-deductible cost, it may increase the tax risk in the event of an inspection, particularly where the nature of the expenditure differs materially from the business activities disclosed in CEIDG or KRS.

Sector-specific risks for selected regulated industries

Following the end of the transitional period, PKD 2007 codes are to be automatically replaced with PKD 2025 codes, in accordance with a mapping scheme developed by Statistics Poland (GUS). However, such a change will not always be possible on a fully automatic basis. If an existing PKD 2007 code corresponds to several different PKD 2025 codes, or if there is no clear equivalent, the existing code may be deleted without being replaced.

Particular caution should therefore be exercised by entities operating in regulated or specialised industries where having a specific business activity listed in the register may be a prerequisite for carrying on the relevant activity, holding a permit or concession, being entered in a specific register, or satisfying other statutory requirements.

In such cases, the automatic deletion of a PKD code without its proper replacement may result not only in outdated information being recorded in the KRS, but also in a risk of non-compliance with the regulations applicable to the relevant industry. Consequently, this may give rise to legal consequences extending beyond the mere need to update the PKD codes.

PKD 2025 – underlying changes and deadlines

The new PKD 2025 classification, effective as of 1 January 2025, has replaced the 2007 codes and has been aligned with EU standards. It is intended to better reflect modern business models and technological development.

Key dates:

• 1 January 2025 – companies commencing business activity and submitting KRS registration applications from this date must already use PKD 2025;
• 31 December 2025 – marks the end of the shortened transitional period for selected industries to adjust PKD codes to PKD 2025;
• 31 December 2026 – marks the end of the full transitional period for most industries; this is the final deadline for voluntary PKD code updates.

Essential information about PKD 2025

PKD 2025 is the mandatory classification of business activities effective in Poland as of 1 January 2025. Every businesses must use codes that accurately reflect their actual business profile. Companies registered before 2025 may update their entries by 31 December 2026 at the latest, but any ongoing update of CEIDG data requires an immediate switch to PKD 2025. Failure to update PKD codes independently may result in automatic reclassification, which carries the risk of errors, potential tax exposure and complications related to financing or grants. The safest approach is to proactively adjust PKD codes before the end of the transitional period.

How to amend PKD codes in a company: the procedure in practice

The procedure depends on whether the company’s business activities are specified in its articles of association using the PKD 2007 classification or described narratively. In either case, the first step before making any formal changes must be to determine the company’s actual business activities and assign the relevant PKD 2025 codes. 

In the first case, the procedure will typically involve two steps, i.e. amending the articles of association before a notary public (or through the S24 system for S24 companies); the amendment must then be registered with the KRS, together with an application to update the company’s PKD codes in accordance with the PKD 2025 classification.

In the second case, the procedure will typically be single-step and involve only submitting an application to the KRS to update the PKD codes in accordance with the PKD 2025 classification.

Restrictions and best practices in the process of selecting PKD codes

• In the National Court Register (KRS), a company may disclose up to 10 PKD codes, including one principal code,
• certain PKD codes are associated with the obligation to obtain a concession, licence, or permit – the mere entry in the register does not entitle the company to conduct regulated activities. 

Summary – a practical checklist for businesses

How should a company approach updating its PKD codes? Below is a recommended, optimal course of action.

Step 1

Audit the PKD codes indicated in the company’s articles of association and in the KRS and assess their consistency with the company’s actual business profile.

Step 2

Select PKD 2025 codes corresponding to the company’s real activities, taking into account the rules for transitioning from PKD 2007 to PKD 2025 (using the so called “mapping keys”). This is particularly important for the IT, e commerce and renewable energy sectors.

Step 3

Amend the company’s articles of association and register both the amended articles and the new PKD codes with the KRS, or update the PKD codes in the KRS without amending the articles (depending on the current wording of the company’s articles of association). It is worth considering combining the PKD update with other KRS changes, as this allows the company to pay a single court fee for the entire package of updates.

Conducting an audit of the PKD codes in use and updating them proactively helps avoid automatic reclassification based on the official “mapping keys”. Automatic reclassification, in turn, may expose the company to real operational risks in its dealings with business counterparties, tax related implications or issues concerning financing and grants. In certain specialised industries, it may also result in non compliance with sector specific regulatory requirements.