PKD 2025 in a company. Requirement to update business codes by 31 December 2026

Companies registered in the KRS before 2025 must update their PKD codes by 31 December 2026. Find out what happens if you miss the deadline and how to do it.

The new Polish Classification of Business Activities, known as PKD 2025, has been in force since 1 January 2025. Entities operating and established before 1 January 2025 are in a transitional period during which their existing PKD codes may remain in the register. This period ends on 31 December 2026. If an entrepreneur does not update their entry independently by that date, they must reckon with the automatic reclassification of codes according to correspondence tables developed by the Central Statistical Office (GUS). This sounds convenient, but it has one significant consequence: the PKD code will not be chosen directly by the entrepreneur in question.

Who is subject to the obligation?

The update applies to entities which, before 2025, had their activity designated with PKD 2007 codes — in practice, all companies entered in the KRS register of entrepreneurs before that date. Entities registered after 1 January 2025 use the new classification from the outset and do not need to make any changes as a result. Sole traders update their codes in CEIDG and do so free of charge.

What happens if no update is made?

Formally, failure to act does not carry sanctions, since reclassification will take place ex officio. The problem lies elsewhere: automatic assignment is based on the existing entry and correspondence tables, and these do not always reflect what the company actually does. Some of the old subclasses have undergone modifications.

The consequences only become apparent later and usually not in the register itself, but in day-to-day operations. The predominant activity code is sometimes used as a reference point, for example when verifying a counterparty or when applying for financing and grants. It may also cause problems with state authorities such as ZUS or the tax office.

Does an update require an amendment to the company's articles of association?

The codes disclosed in the register must correspond to the objects of the company as defined in its articles of association or statute. If the new designations fall within the existing entry, a request to change the register entry is sufficient. If they do not, an amendment to the articles will first be necessary, and the procedure and form of that amendment depend on the type of company and on how its objects are formulated. It is therefore worth starting the update not from the register, but from reading the articles of association, since they determine whether the matter ends with a single application or requires a prior shareholders' resolution — and, in some cases, notarial form.

If an amendment to the articles of association proves necessary, it is worth considering whether to treat it more broadly than merely as a correction of designations. Articles concluded several, or sometimes more than twenty, years ago often contain provisions that correspond neither to the current wording of the law nor to the way in which the entity (e.g. a partnership) operates today. Updating the PKD codes may therefore become an opportunity to review the operating rules of the entity in question.

Are there any costs involved in updating PKD?

To answer the question that is asked most often directly: the update of PKD codes for entities registered in the KRS is not exempt from fees. The legislator has not provided any preference for it, despite the fact that the obligation arises from a change in classification imposed from above, and not from the entrepreneur's own decision. If an amendment to the company's articles of association is necessary, court fees may be supplemented by, among other things, notarial costs if such form applies to the entity in question. In companies using the template in the S24 system, fees are lower than in the case of applications submitted via the PRS system.

How to do it in practice?

1. Check the company's articles of association. Establish whether the new codes will fit within the objects of the company as described in the articles.
2. Compare the current codes with the new classification. Use the PKD 2007 to PKD 2025 transition tables and verify whether the assignment corresponds to what the company actually does.
3. Adopt a resolution. On the amendment of the company's articles of association, if that is necessary.
4. Submit an application to the competent registration court. The application is submitted electronically and signed with a qualified electronic signature, a trusted signature or a personal signature.

Why is it worth making the change independently?

An independent update allows you to consciously designate the predominant and remaining activities, and to remove codes that have not reflected reality for years — while fitting within the limit of ten entries, one of which is designated as the predominant activity. Automatic reclassification will not do this, since it operates on the basis of what is already in the register, and not on the basis of what the company is actually engaged in at present.

Updating the codes is an administrative matter and in a typical situation is not among the complex ones. It is worth treating it as an opportunity to review the register entry, however, rather than as a formality to be put off until the final weeks of the year.