Employee benefits tax treatment 2026/2027: PIT, ZUS and ZFŚS in one table (25 benefits)

The same voucher can cost the company and the employee very different amounts depending on whether it was funded by the Company Social Benefits Fund (ZFŚS) or by the company's budget. A lunch card is free of ZUS contributions up to PLN 450 a month, but full income tax must be withheld on it. A nursery subsidy may be exempt from PIT and still be included in the contribution base. Employee benefit settlement is today one of the areas where HR and accounting most easily make costly mistakes, especially at the end of the year, when ZFŚS funds are distributed and the budget for the next year is planned.

Below you will find an overview of 25 popular benefits: whether they are subject to PIT (Polish personal income tax), whether they are included in the ZUS (social security) contribution base, whether they come from the ZFŚS or company funds, what limit applies and which provision it follows from. Legal status: 9 November 2026.

Short answer

• Two things determine how a benefit is settled: the source of funding (ZFŚS or company funds) and the form of the benefit (goods, a service, cash or a voucher).
• Benefits from the ZFŚS are not included in the ZUS contribution base. For PIT, in-kind and cash benefits from the ZFŚS are exempt up to a combined PLN 1,000 a year, but vouchers, coupons and gift cards from the ZFŚS are taxed from the first złoty.
• Benefits from company funds are, as a rule, employee income and are subject to PIT and contributions. The exceptions are listed in the PIT Act and in the contributions regulation, and these two lists do not overlap.
• As of 9 November 2026, no changes to the exemptions in this table entering into force on 1 January 2027 have been published in the Journal of Laws. The confirmed change concerns nursery and preschool subsidies from company funds and takes effect on 1 January 2028.

Table: employee benefits tax treatment – PIT, ZUS and ZFŚS (25 benefits)

In the ZUS column, "no contributions" means exclusion from the basis for social insurance contributions. The basis for the health contribution and for Labour Fund and FGŚP contributions is set using the same rules. The "contributions regulation" is the Regulation of the Minister of Labour and Social Policy of 18 December 1998 on the detailed rules for determining the basis for pension and disability contributions.

The table shows whether a benefit is income and whether it is included in the contribution base. It does not depend on tax rates.

How to read the table: three rules

The source of funding changes everything

The PIT Act treats as employment income all payments and benefits in kind "regardless of the source of funding" (Art. 12(1)). The exemptions, however, are tied to specific sources. The same subsidy for a child's summer camp is exempt without limit if it comes from the ZFŚS, but from company funds only up to PLN 2,000 a year. The same sports card from the ZFŚS is not included in the contribution base, but paid in full by the company it is.

PIT and ZUS are two separate lists

An employee's contribution base is income within the meaning of the PIT Act, except for the items listed in § 2 of the contributions regulation. A tax exemption therefore does not automatically mean an exemption from contributions. The nursery subsidy from company funds shows this best: for PIT it is exempt up to PLN 1,000 a month per child, but the contributions regulation excludes from the base only benefits from the ZFŚS. It also works the other way round – a lunch card has no PIT exemption, but for ZUS it has a limit of PLN 450 a month.

A voucher is not an in-kind benefit

Art. 21(1)(67) of the PIT Act states expressly that "vouchers, coupons and other tokens entitling the holder to exchange them for goods or services are not in-kind benefits". That is why a package from the ZFŚS falls within the PLN 1,000 limit, while a ZFŚS voucher of the same value is taxed from the first złoty. We described this in detail in our compendium on vouchers and prepaid cards, and in a Christmas context in the article on Christmas vouchers and gift packages 2026. When a benefit becomes employee income is also covered in our article on tax-deductible costs and benefits.

ZFŚS benefits and tax: the PLN 1,000 limit and the social criterion

The exemption in Art. 21(1)(67) of the PIT Act covers in-kind and cash benefits related to social activities, funded entirely from the ZFŚS or trade union funds, up to a combined PLN 1,000 per employee in the tax year. The limit is annual and shared. Any amount above PLN 1,000 is income from which the employer, as payer, withholds a tax advance.

Three separate exemptions apply to ZFŚS benefits outside this limit:

• subsidies for children's stays in nurseries, children's clubs and preschools (Art. 21(1)(67a)) – no amount limit;
• subsidies for organised leisure for children and young people up to 18 (Art. 21(1)(78)(a)) – no amount limit;
• hardship allowances in the event of random events, natural disasters, long-term illness or death (Art. 21(1)(26)(a)) – no amount limit.

On the ZUS side the rule is simpler: § 2(1)(19) of the contributions regulation excludes from the base all benefits funded from the ZFŚS for social purposes, regardless of form and amount. The condition, however, is compliance with the ZFŚS Act, which requires that the granting of benefits and the amount of subsidies depend on the life, family and financial situation of the eligible person (Art. 8(1)). A benefit granted to everyone equally, without assessing that situation, is the most common source of disputes during inspections. More on what the fund may be spent on in What can ZFŚS funds be used for.

The basic ZFŚS write-off in 2026 is PLN 2,943.23 per employee working in normal conditions. This is 37.5% of the average wage in the second half of 2025 (PLN 7,848.60 according to the notice of the President of Statistics Poland (GUS) of 19 February 2026, Monitor Polski item 232), which was higher than the average for the whole of 2025 (Art. 5(2) of the ZFŚS Act). The 2027 write-off is not yet known – the President of GUS announces the basis for calculating it in Monitor Polski by 20 February each year (Art. 5(7)).

Lunch card: PLN 450 free of contributions, but taxed

A lunch card funded by the employer is employee income and is subject to PIT. The PIT Act exempts meals only when they result from health and safety obligations (Art. 21(1)(11) and (11b)). For contributions, § 2(1)(11) of the contributions regulation applies: the base excludes the value of meals provided without the right to a cash equivalent, and of vouchers, coupons and prepaid cards entitling the holder to buy only meals in catering or retail outlets – up to PLN 450 a month.

ZUS clarified the boundaries of this exclusion in individual ruling DI/100000/43/1024/2026 of 16 February 2026:

• the exclusion covers ready meals and products suitable for immediate consumption, not grocery shopping in general;
• the card must not allow cash withdrawals;
• the burden of proving that the funds were spent as intended lies with the employer;
• the PLN 450 limit applies to each month separately – an unused amount does not carry over to the next month, and spending on meals above PLN 450 in a given month is included in the contribution base.

The ruling binds ZUS only with respect to the business that requested it, but it shows the authority's approach well. You will find full guidance in the article Lunch card: a complete tax guide for employers 2026.

Sports card and medical package: when free of ZUS contributions

For PIT, a sports card and a medical package paid by the employer are employee income – the act provides no exemption for them. The exception is a sports card funded entirely from the ZFŚS: in an individual ruling of 30 October 2019 (ref. 0115-KDIT2-2.4011.349.2019.1.MU), the Director of KIS recognised it as a benefit falling within the PLN 1,000 limit under Art. 21(1)(67).

For contributions, the outcome depends on how the benefit is structured. In ruling DI/100000/43/1486/2026 of 27 May 2026, ZUS (Gdańsk branch) accepted as correct excluding from the contribution base the employer-funded part of a medical package, medical insurance and sports package if:

• the right to buy it follows from the remuneration rules or internal pay regulations,
• the employee buys the package at a price lower than retail and bears part of the cost, even a token one.

The basis is § 2(1)(26) of the contributions regulation, which excludes material benefits consisting of the right to buy at prices lower than retail. The difference between the package price and the employee's co-payment is excluded from the base. When the company pays for the card or package in full, this provision does not apply and the value of the benefit is included in the contribution base.

What changes in 2027 (and in 2028)

We checked the acts amending the PIT Act, the contributions regulation and the ZFŚS Act published in the Journal of Laws up to 9 November 2026. The result:

• No change to the exemptions in the table enters into force on 1 January 2027. The PLN 1,000 limit under Art. 21(1)(67), the PLN 450 limit for meals and the other amounts remain unchanged.
• From 1 January 2028 the wording of Art. 21(1)(67b) of the PIT Act will change (Act of 31 July 2026 amending the Act on care for children under 3 and certain other acts, Journal of Laws 2026, item 1123). The exemption will cover subsidies for a nursery, children's club, day care point, preschool, preschool class in a primary school or other form of preschool education. The limit of PLN 1,000 a month per child remains.
• The contributions regulation has not been amended since 1 September 2023.
• The 2027 ZFŚS write-off will be known after the notice of the President of GUS (by 20 February 2027).
• As of 9 November 2026, the act changing the tax scale has not been published in the Journal of Laws. The scale under Art. 27(1) of the PIT Act applies (12% up to PLN 120,000 and 32% on the excess). The table does not depend on it, because it shows whether a benefit is income, not how much tax will be due.

How a cafeteria separates ZFŚS funds and company funds

Most mistakes arise when an employee chooses a benefit from one pool and accounting does not know which budget paid for it. A benefits cafeteria sorts this out at the configuration level:

1. Separate budgets. ZFŚS funds and company funds reach the employee as separate point pools, and each benefit is assigned a source of funding.
2. ZFŚS allocation rules. The size of the social pool can be differentiated according to thresholds set in the fund's rules, which makes it easier to apply the social criterion.
3. Form of the benefit. For the PLN 1,000 limit, what matters is whether the employee chose an in-kind benefit or a voucher – the cafeteria report lets you separate this before running payroll.
4. Payroll report. The value of benefits broken down by source and form goes to payroll, which adds the income and sets the contribution base.

We write more about spending the social fund this way in Benefit cafeteria and ZFŚS. When a company wants to give employees a one-off choice, for example for the holidays, Nais eVouchers (page in Polish) are a solution. For tax purposes an eVoucher is a voucher: from the ZFŚS it is subject to PIT from the first złoty but free of contributions, and from company funds it is subject to PIT and contributions. Costs and settlement of company events are described in the article on the company Christmas party and employee gifts 2026.

Frequently asked questions

Are ZFŚS benefits tax-free?

Not all of them. In-kind and cash benefits from the ZFŚS are exempt from PIT up to a combined PLN 1,000 a year, and subsidies for nurseries and preschools, children's leisure and hardship allowances – without limit. Vouchers and gift cards from the ZFŚS are taxed from the first złoty. None of these benefits is included in the ZUS contribution base.

Is a lunch card exempt from ZUS?

Yes, up to PLN 450 a month, if it entitles the holder only to buy meals in catering or retail outlets and cannot be exchanged for cash. However, a PIT advance must be withheld on its full value.

Is a sports card subject to contributions?

Paid in full by the company – yes. From the ZFŚS – no. With an employee co-payment and a provision in the remuneration rules, ZUS in its ruling of 27 May 2026 accepted that the employer-funded part may be excluded from the contribution base.

Does a PIT exemption mean an exemption from ZUS?

No. The contribution base is income under the PIT Act minus the items in § 2 of the contributions regulation. An example is the nursery subsidy from company funds: exempt from PIT up to PLN 1,000 a month per child, but not excluded from contributions.

Will the PLN 1,000 ZFŚS limit increase from 2027?

As of 9 November 2026, no change to this limit has been published in the Journal of Laws. From 1 January 2027 it therefore remains PLN 1,000 a year.

Are employer PPK contributions employee income?

Yes. Employer-funded contributions are employee income and are subject to PIT, but they are not included in the basis for pension and disability contributions (Art. 26(5) of the PPK Act).

Sources and legal status

Legal status as of 9 November 2026. All provisions were checked in consolidated texts and amending acts published in the Journal of Laws.

• Personal Income Tax Act, consolidated text Journal of Laws 2026, item 592 – Art. 12(1) and (2a)–(2c), Art. 21(1)(11), (11b), (26), (67), (67a), (67b), (78), (90), Art. 27(1).
• Regulation of the Minister of Labour and Social Policy of 18 December 1998 on the detailed rules for determining the basis for pension and disability contributions, consolidated text Journal of Laws 2025, item 316 – § 1 and § 2(1)(6), (11), (19), (21), (22), (26), (29).
• Act on the Company Social Benefits Fund, consolidated text Journal of Laws 2024, item 288, as amended by Journal of Laws 2026, item 25 – Art. 3, 5, 8.
• Notice of the President of GUS of 19 February 2026, Monitor Polski 2026, item 232.
• Employee Capital Plans (PPK) Act, consolidated text Journal of Laws 2026, item 192 – Art. 26; mojeppk.pl portal – PIT on employer contributions.
• Employee Pension Programmes (PPE) Act, consolidated text Journal of Laws 2026, item 777 – Art. 24; rodzinaipraca.gov.pl – taxation of the basic contribution.
• Labour Code, consolidated text Journal of Laws 2026, item 1245 – Art. 67²⁴ and 67²⁵.
• Act of 31 July 2026, Journal of Laws 2026, item 1123 – Art. 4 (amendment of Art. 21(1)(67b) from 1 January 2028).
• Regulation of the Minister of Labour and Social Policy of 1 December 1998 on health and safety at workstations equipped with screens (Journal of Laws 1998 No. 148, item 973, as amended) – § 8(2).
• ZUS individual rulings: DI/100000/43/1024/2026 of 16 February 2026 (lunch cards) and DI/100000/43/1486/2026 of 27 May 2026 (medical packages and sports cards).
• Individual ruling of the Director of KIS of 30 October 2019, ref. 0115-KDIT2-2.4011.349.2019.1.MU (sports card from the ZFŚS).

Legal disclaimer

This article is for information only and does not constitute legal or tax advice. It describes the legal position as of 9 November 2026. Individual rulings bind the authority only with respect to the entity that requested them. The rules may change after the verification date, so before making a decision check the current wording of the law in the Journal of Laws (Dziennik Ustaw) or ISAP, or consult a tax adviser.

Summary: checklist for HR

1. For each benefit, establish the source of funding: ZFŚS or company funds.
2. Establish the form: goods or a service, cash or a voucher. Vouchers from the ZFŚS do not benefit from the PLN 1,000 limit.
3. Check PIT and ZUS separately – an exemption in one list does not mean an exemption in the other.
4. Keep track of periodic limits: PLN 1,000 a year from the ZFŚS, PLN 450 a month for meals, PLN 1,000 a month per child for nursery and preschool subsidies from company funds.
5. For sports cards and medical packages with an employee co-payment, record the entitlement in the remuneration rules.
6. Grant ZFŚS benefits according to the social criterion described in the fund's rules.
7. At the beginning of 2027, recalculate the ZFŚS write-off after the GUS notice.

If you want the split between the ZFŚS and company funds to be visible as soon as an employee chooses a benefit, and payroll to receive a ready report, see how the Nais cafeteria works.