Christmas Vouchers and Gift Packages 2026: PIT and ZUS from the ZFŚS and Operating Funds (Table + PLN 1,000 Limit)
Legal status: 2 November 2026
For many organisations, the question of how Christmas vouchers funded from the ZFŚS (Company Social Benefits Fund) are taxed requires a careful look at the rules for PIT (personal income tax) advances and ZUS (social security) contributions. From an accounting perspective, two things matter most: the source of funding and the type of benefit chosen.
1. Short answer: gift package, voucher and the PLN 1,000 limit
A gift package in kind funded entirely from the ZFŚS is exempt from PIT up to PLN 1,000 per employee per year and is not subject to ZUS contributions, whereas a voucher or gift card funded from the ZFŚS does not qualify for this exemption – PIT must be withheld from the very first złoty, although there are still no ZUS contributions. The same gift bought from the company's operating funds is ordinary employment income: it is subject to PIT and full ZUS contributions. If you want to give employees a choice instead of a package, Nais eVouchers are settled like a voucher – what matters is the source of funding.
2. Table: Christmas gift package and voucher from the ZFŚS and from operating funds – PIT and ZUS
To put the settlement rules in order, we have prepared an overview of the most popular forms of Christmas benefits and their tax and contribution burden depending on which budget they come from.
For CIT (corporate income tax) purposes, the deductible cost is the contribution transferred to the ZFŚS (Art. 16(1)(9)(b)), not the expenditure made from the fund (Art. 16(1)(45)). Costs are discussed in more detail in our article on the company Christmas party.
3. The PLN 1,000 limit under Art. 21(1)(67) – what counts towards it
Under the Personal Income Tax Act (Journal of Laws 2026, item 592), the value of benefits in kind, and cash benefits received in this respect, that an employee receives in connection with the financing of social activities referred to in the regulations on the Company Social Benefits Fund (ZFŚS), financed entirely from the ZFŚS or trade union funds, is exempt from income tax. The exemption limit is PLN 1,000 per tax year.
From the HR department's perspective, the key is to add up the benefits correctly. The PLN 1,000 limit is annual and covers, in total, all benefits in kind (e.g. Christmas gift packages for employees in 2026, anniversary gifts) and cash benefits (e.g. holiday subsidies, hardship allowances) financed from the fund in a given year.
If the value of benefits exceeds PLN 1,000 in a year, any excess is the employee's income, on which the employer must calculate and withhold a PIT advance. Remember that the Act expressly excludes vouchers from the definition of a benefit in kind (more on this in the next section), which means the value of vouchers handed out does not use up the PLN 1,000 limit. Examples and restrictions on spending the fund are described in detail in our article: What ZFŚS funds can be used for.
4. Why a ZFŚS voucher is subject to PIT but not ZUS
The tax treatment of Christmas vouchers funded from the ZFŚS follows directly from how the tax and social security provisions are drafted.
Under Art. 21(1)(67) of the PIT Act quoted above, the exemption applies to benefits in kind and cash benefits. However, the same provision clearly states that vouchers, coupons and other tokens entitling the holder to exchange them for goods or services are not benefits in kind. Because of this exclusion, every voucher, coupon, gift card or prepaid card financed from the ZFŚS is taxable income for the employee from the very first złoty. The employer adds its value to the salary for the month and withholds the tax advance.
Social security is a different matter. Under § 2(1)(19) of the Regulation of the Minister of Labour and Social Policy on the detailed rules for determining the basis for pension and disability contributions (Journal of Laws 2025, item 316), benefits financed from funds allocated to social purposes within the ZFŚS are excluded from the contribution base. The regulation does not distinguish between benefits in kind, cash benefits or vouchers. As long as the benefit comes from the ZFŚS and meets the requirements of the Act on the fund, it is not subject to contributions.
The social criterion must, however, be strictly observed. The ZFŚS Act requires that subsidised services and benefits, and the amount of subsidies, depend on the life, family and financial situation of the eligible person. Handing out vouchers or packages of identical value to all employees "equally", without examining their financial situation, is a risk in an inspection – ZUS may challenge the contribution exemption.
5. A Christmas gift from operating funds: PIT and ZUS
Not every organisation has a social fund, and some have decided to finance Christmas gifts directly from the employer's operating funds.
Under Art. 12(1) of the PIT Act, employment income includes all cash payments and the cash value of benefits in kind or their equivalents, regardless of how those payments and benefits are financed. ZUS and the tax office treat a gift package, voucher or Christmas present funded from operating funds exactly like base salary.
The value of such a gift must be added to the employee's tax base (PIT) and to the base for social security and health insurance contributions in the month it is given. The contributions regulation provides no exclusions here – § 2(1)(26) only covers material benefits consisting of the right to buy goods or services at prices lower than retail, not benefits given entirely free of charge. An extended discussion of these rules can be found in our tax compendium on vouchers and prepaid cards.
6. Will the PLN 1,000 limit increase in 2027?
Questions about indexing the PIT exemption limit come up regularly. In mid-2026, raising the amount became the subject of official correspondence. In a letter from the Commissioner for Human Rights (RPO) to the Ministry of Finance dated 12 June 2026, an increase of the exemption limit to PLN 2,000 was proposed.
In its reply of 7 July 2026, the Ministry of Finance declined. As of 2 November 2026, there is no draft law changing the PLN 1,000 limit under Art. 21(1)(67) for 2027.
7. How Nais eVouchers solve the Christmas package-or-voucher dilemma
Managing traditional Christmas packages is a major logistical challenge for HR departments: from choosing the contents and struggling to meet employees' different preferences, to storage and physical distribution of boxes. A classic physical voucher, on the other hand, is usually tied to one specific retail chain, which limits choice.
Nais digital vouchers remove logistics, storage and shipping. The recipient chooses a reward from thousands of offers in the Nais ecosystem, while the company sets the value of the benefit, its expiry date and the rules of use. Generating hundreds of vouchers takes a few minutes. The code is activated online, and codes reach recipients directly or through the organisation.
From a payroll perspective, the rules are transparent. An eVoucher is a voucher, which means that if it is financed from the ZFŚS (applying the social criterion), it is subject to PIT from the first złoty but exempt from ZUS contributions. When it is financed from operating funds, full PIT and ZUS apply. The fixed value set by the company makes it easy for HR and payroll to add the correct income to the payroll. For a broader view of the topic, see the article: Benefit cafeteria and the ZFŚS.
8. Frequently asked questions (FAQ)
Are Christmas vouchers from the ZFŚS taxed? Yes, vouchers financed from the ZFŚS are subject to PIT from the first złoty because they are not considered a benefit in kind; however, no ZUS contributions are charged on them.
A Christmas gift from operating funds and ZUS – do contributions have to be paid? Yes, benefits financed from operating funds are standard employee income and are subject to full ZUS contributions and PIT.
Does the PLN 1,000 limit apply to a single benefit or the whole year? The limit applies to the whole tax year. It covers, in total, all benefits in kind and cash benefits financed for the employee from the ZFŚS in a given year.
Can a Christmas package from the ZFŚS be the same for everyone? Giving packages equally is risky. The ZFŚS Act strictly requires the social criterion (making support dependent on the employee's financial and life situation); without it, ZUS may challenge the contribution exemption.
Will the PLN 1,000 limit increase in 2027? As of 2 November 2026, there is no draft amendment in this area, and the Ministry of Finance has previously rejected the RPO's proposals to raise the amount.
This article is for information only and does not constitute legal or tax advice. Legal status as of 2 November 2026. Before making a decision, consult a tax adviser or your accounting team.
If this year you want to give employees a choice instead of packages, check out Nais eVouchers: you set the value and expiry date, and each employee decides how to use the voucher. You can also make Christmas funds available in the Nais cafeteria.
