Electronic Delivery Address for Sole Traders from 1 October 2026. What Really Changes?

From 1 October 2026, sole traders registered in CEIDG before 2025 must have an electronic delivery address. I explain what this means in practice and where the real risk lies.

If you run a sole proprietorship registered in CEIDG before 1 January 2025, from 1 October 2026 you are required to have an electronic delivery address. A great deal of confusion has built up around this deadline regarding the practical consequences of the enacted provisions. It is worth looking at what the law actually says, whether entities subject to this obligation face any sanctions for failing to register an electronic delivery address, and where the real risks lie for entrepreneurs who do have such an address.

Who Does the 1 October 2026 Deadline Apply To?

The obligation to hold an electronic delivery address registered in the electronic address database is imposed on non-public entities by Article 9(1) of the Act of 18 November 2020 on Electronic Delivery. The legislature phased it in over time: members of regulated professions were covered from 1 January 2025, companies registered in the National Court Register before 1 January 2025 from 1 April 2025, and entrepreneurs registered in CEIDG by 31 December 2024 have until 1 October 2026. Anyone registering a business after 1 January 2025 provides the data for creating the address in the registration application itself.

There is a trap here. The October deadline applies only to those who have not touched their entry throughout this entire period. If you submitted any application to amend your CEIDG entry after 30 June 2025 - even to change a PKD code, address or contact details - the obligation to provide data for creating the address arose at that point. Many sole traders have therefore already been in the system for months.

Will You Stop Receiving Correspondence Without an Address?

As a rule, no - and that conclusion follows from an analysis of the provisions of the Electronic Delivery Act. The rule is set out in Article 4(1) of the Act: a public entity delivers correspondence requiring confirmation of dispatch or receipt to the electronic delivery address registered in the electronic address database. However, the legislature provided for what happens when no such address exists.

The answer is given by Article 5 of the Act, under which, where it is not possible to deliver correspondence to an electronic delivery address, a public entity delivers it using the public hybrid service. That service is defined in Article 2(7) of the Act as a postal service provided by the designated operator - currently Poczta Polska - where the sender is a public entity. In practice, the authority sends the document electronically, and the operator prints it, packages it and delivers it to your address as a traditional letter.

The mechanism was designed precisely to avoid excluding from the system those who do not use an electronic address. It does, however, have limits, set out in Article 6 of the Act, which excludes the hybrid service in cases including where the addressee requests delivery of the original of a document originally drawn up in paper form, where conversion of the document is not possible, or where an important public interest so requires. Article 6 sets out exceptions to Articles 4 and 5 of the Act.

Is There a Penalty for Not Having an Address?

The Electronic Delivery Act does not provide for criminal or administrative sanctions for failure to fulfil the obligation under Article 9(1). It does not provide for them in relation to public entities subject to the same obligation either. There are also no enforcement proceedings: registration courts do not have the powers they hold in respect of, for example, financial statements. The result is that the obligation exists, but no mechanism for actually enforcing it accompanies it.

This does not mean the obligation can be ignored. Failing to fulfil it may result in slower processing of matters and communication with authorities conducted via a channel that, for public administration, is now the exception rather than the rule. Since 1 January 2026, the transitional period has ended and electronic delivery has become the primary channel of correspondence for public entities.

Where Does the Real Risk Lie?

The paradox is that the risk arises only once you already have the address. Under Article 7(1) of the Act, entry of an address in the electronic address database is equivalent to a request that public entities deliver correspondence to that address. From that moment, as a rule, all correspondence reaches the entrepreneur via the electronic mailbox.

This brings the deemed delivery rule into play. Article 41(1)(3) of the Act provides that proof of receipt is issued after 14 days from the date on which correspondence arrives at the address of the non-public entity, if the addressee has not collected it earlier. Article 42(2) adds the consequence: the correspondence is then deemed delivered on the day following the expiry of those 14 days (deemed delivery). A letter you never opened is therefore delivered, and any deadlines for action begin to run.

Practical Notes

Article 41(3) of the Act defines the arrival of a document as the occurrence of technical conditions enabling the addressee to collect it. The fourteen-day period is therefore triggered by a technical event that the addressee, without exercising appropriate diligence, may fail to notice or may overlook. It is therefore important to check regularly for notifications regarding correspondence received in the electronic mailbox.

The consequences are very real. If you open correspondence in your electronic mailbox, for example, only on the twentieth day after it arrived, the letter is in fact already treated as having been effectively delivered five days ago. This is particularly important when communicating with public authorities, especially when a decision in a matter is being served. Bear in mind the limited time for lodging, for example, appeals (standardly 14 days from delivery). Oversights can be very costly in some situations.

Recommended Actions

• Check whether you already have an electronic delivery address.
• Set up the address in advance, not in the last week of September. The application is submitted through Biznes.gov.pl.
• Decide who will actually manage the mailbox. You can manage it yourself or appoint an administrator. The important thing is to check regularly whether any new correspondence has arrived.
• Remember that a business address (sole proprietorship) is not the same as a private address.

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