Excessive Burdens and Oversight of Microenterprises - a commentary by the Scientific Council of the SME Ombudsman
17th June 2026
Looking back over recent years, it is clear that the regulatory environment is becoming increasingly demanding. The number of reporting obligations has increased, as has the scope of audits conducted by the National Revenue Administration (KAS).
Examples include projects that Paweł Kossecki and other members worked on as part of the Scientific Council of the Ombudsman for Small and Medium-Sized Enterprises, such as KSeF and JPK CIT. KSeF has already been implemented for most entities, and by 2027 it will also cover all remaining ones. The implementation process for JPK CIT follows a similar pattern; starting in 2027, it will apply to additional groups of taxpayers. Entrepreneurs must prepare for further changes related to reporting and the digitization of tax processes.
Every new change requires businesses to devote time and resources to adapting their operations to evolving requirements. This includes, among other things, implementing appropriate technological solutions, integrating systems, updating procedures, and training employees. However, for some changes targeting the SME sector, there are concerns regarding the principle of proportionality when it comes to imposing additional reporting obligations. Another challenge is how to communicate the new requirements, which often rely on complex language and digital solutions that are not always intuitive for the audience.
The ability to adapt is one of the key factors influencing business competitiveness today. While some companies are efficiently implementing new solutions, for others the pace and scale of change pose significant organizational and financial challenges, which may consequently lead to the gradual disappearance of micro, small, and medium-sized entities from the market. Similar processes are also taking place in the accounting services market. Growing regulatory and technological requirements mean that not all accounting firms have the resources to effectively implement new obligations. As a result, we can expect a progressive consolidation of the accounting services market.
At the same time, there has been an increase in enforcement activity by tax authorities, particularly regarding the application of VAT rates. A widely discussed case involved a Gdańsk pizzeria whose VAT rate for shrimp pizza was challenged. As a result, the business owner was fined for applying an 8% rate instead of 23%. Until now, such audits typically resulted in a warning from the tax office; now, however, substantial fines are being issued. The increased number of audits may be linked to performance metrics currently in place within the tax administration.
