From 1 January 2027, the automatic reclassification of PKD 2007 codes into PKD 2025 codes will begin in Commercial Register. Companies have until 31 December 2026 to change their PKD codes themselves and retain control over how their business activities are described in the registers.
Why was PKD 2025 introduced?
The Polish Classification of Activities 2025, introduced by the Regulation of the Council of Ministers of 18 December 2024, has been in force since 1 January 2025. The new classification replaced PKD 2007. The purpose of the changes was to adapt the descriptions to current economic realities, including the development of the digital economy, circular economy, bioeconomy and new business models, and to reflect companies’ actual activities more accurately. At the same time, the descriptions of many traditional types of activity were clarified.
Until when can PKD codes be changed independently?
Entities whose activities were classified under PKD 2007 before 1 January 2025 may continue to use the previous classification until 31 December 2026. Therefore, a business may currently select the PKD 2025 codes corresponding to the activities it actually conducts and notify them to the relevant register. Entities registered after 1 January 2025 and entities submitting applications that require the subject of their activities to be stated after that date should already use PKD 2025.
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Until 31 December 2026, entities may update their codes themselves and decide which PKD 2025 designations best describe their activities. Waiting for automatic reclassification means leaving this choice to a mechanism based on official correlation tables and creates a risk of a mismatch or even the deletion of a code.
How will the automatic reclassification of PKD codes work?
After the end of the transitional period, i.e. from the beginning of 2027, codes not updated by companies are to be reclassified ex officio in the KRS. The mechanism was established by the Act of 21 November 2025 amending the Act on Public Statistics and certain other acts.
Additionally, for companies, Article 20e of the Act on the National Court Register provides for the automatic reclassification of PKD codes. The automatic change will be based on the relationships between PKD 2007 and PKD 2025. If exactly one new code corresponds to an old code, the reclassification should be relatively straightforward. Ambiguous relationships require greater attention, for example where one PKD 2007 code corresponds to several PKD 2025 codes or the new designation covers a different scope of activity than the previous code. Furthermore, Article 22(2) of the Act on the National Court Register provides that where the predominant activity is deleted from the Register under Article 20e(1)(3), an entity entered in the register of entrepreneurs must report its predominant activity under the new Polish Classification of Activities (PKD) with its first application toamend data in the Register, but no later than five years after the deletion. This provision therefore applies where the predominant activity code is deleted entirely without an appropriate PKD 2025 code being assigned automatically. In such a case, the business has five years to report a new code. However, remaining for such a long period without a predominant activity code disclosed in the KRS does not appear desirable.
Can the automatic change of PKD codes be risky?
Yes. The automatic mechanism does not analyse the business’s actual activity profile individually. If the mapping is ambiguous, the result may not fully reflect the activities actually conducted. For example, the previous code for electricity generation has been divided in PKD 2025 into more detailed subclasses covering, among others, wind, solar, geothermal, biogas and hydropower generation.
An incorrect or overly general code may have practical significance where PKD designations are verified in connection with financing, grants, permits, concessions or tenders. In the case of the CEIDG, where automatic matching proves impossible, the regulations also allow an unmatched code to be deleted after 31 January 2027.
Article 22(2) also provides for the deletion of a PKD code without automatic reclassification, which may result in the company having no subject of activity disclosed in the KRS at all.
What should a company do before the end of 2026?
First, it is worth obtaining a current extract or printout from the relevant register and determining which codes are outdated. They should then be compared with the PKD 2025 descriptions and the GUS correlation tables, taking into account the activities actually performed rather than merely the similarity of code names. It should also be verified whether adjusting the subject of activity requires an amendment to the articles of association and the adoption of an appropriate resolution.
Companies entered in the KRS may limit themselves to updating the PKD codes disclosed in the register, without amending the company agreement, provided that the scope of activity specified in the agreement still covers the activities corresponding to the new PKD codes. In practice, however, it is worth treating the change of classification as an opportunity to comprehensively organise
the subject of activity and align all codes stated in the articles of associations with PKD 2025. In that case, a resolution amending the articles of association must be adopted in the form required by law, followed by an application to the KRS to amend the data. This approach will ensure full consistency between the wording of the company agreement and the KRS entry and will reduce the risk of doubts in subsequent registration proceedings or other activities requiring verification of the subject of activity.
Once the appropriate codes have been selected, an updating application should be filed with the relevant register. Earlier verification helps avoid acting under time pressure and makes it possible to check the consistency of the codes with corporate documents, sector-specific requirements and the conditions for using concessions, permits or support instruments.
Table: PKD 2025 – deadlines and actions for businesses”
| Deadline | What happens? | Recommendedaction |
|---|---|---|
| By 31 December2026 | Parallel use of PKD 2007 and PKD 2025 for earlier entries | Independent analysis and update of codes |
| From 1 January2027 | Automatic reclassification of codes that have not been updated | Verification of the result in the register |
The legislature has left companies a choice as to whether they wish to independently verify and influence the content of the data made available in Commercial Register. The data of entities that do not take action themselves will be changed ex officio, without the business’s participation or influence. However, the automatic reclassification of PKD codes at the beginning of 2027 will not replace an assessment of which PKD 2025 designations correspond to the activities actually conducted. From legal and organisational perspective, changing the PKD codes independently before the end of 2026 is the safer solution and, for companies, this should also include amending the provisions of the company agreement or articles of association.
