Which businesses fall within the 1 October 2026 deadline?
The deadline primarily affects natural persons entered in CEIDG by 31 December 2024 who still do not have an e-Delivery address in the Electronic Address Database. The original registration date is not the only relevant fact.
Where such a trader applied to amend the CEIDG entry after 30 June 2025, the obligation arose earlier, from 1 July 2025. A review should therefore cover the filing history, not merely the current registry extract.
New sole traders registering from 1 January 2025 provide the information needed for the address as part of the registration process. Companies registered in the National Court Register follow a different timetable: entities already in that register before 2025 became subject to the requirement from 1 April 2025. The CEIDG deadline should therefore not be applied to a Polish limited liability company.
Does a suspended sole-trader business still need an address?
Yes. The official guidance states that the obligation also applies to suspended businesses. Suspension restricts ongoing business activity, but it does not remove the CEIDG entry or eliminate official matters concerning the trader.
If the business is expected to resume only after 1 October 2026, the safer approach is still to complete implementation before that date. Waiting until resumption can create a period in which the legal requirement has not been met or an activated mailbox is not monitored.
Why is submitting the application not enough?
The process involves several stages: filing the application, verifying the applicant’s authority, creating the address, activating the mailbox and recording the address in the database. Representation documents may be required where someone acts for the trader.
Once the address has been created, the user must access and activate the mailbox. Notifications and administrator access should then be configured. If a qualified private trust-service provider is used, the contract should also be reviewed for integrations, responsibility, continuity and the export of dispatch and receipt evidence.
How the issue appears in practice
Practical example — hypothetical scenario
A consultant has been registered in CEIDG since 2018 and suspends the business for six months. Paper correspondence is collected at the consultant’s home address, so the owner assumes e-Deliveries can wait until the business resumes. An application is submitted in August 2026, but the new mailbox is not activated and no notifications are configured. The risk is not merely a technical omission. Once the address becomes operational, official correspondence may reach a channel that is not monitored. A response or procedural deadline may then be missed under the rules governing the particular matter. A proper implementation would verify the database status, activate the mailbox, configure two independent notifications, document the routing of incoming documents and provide cover during absence. The owner should also agree which documents go directly to the accountant and which require legal review first.
How should the mailbox be managed?
An e-Delivery address is a channel for correspondence with legal consequences, not another marketing inbox. The internal process should identify:
- a primary administrator and a substitute;
- how frequently the mailbox is checked;
- where new-message notifications are sent;
- how receipt is logged and deadlines are escalated;
- when a document is sent to accounting, legal counsel or another function;
- how access is removed when an employee or adviser changes; and
- how correspondence and evidence of dispatch or receipt are retained.
Legal basis
- Act of 18 November 2020 on Electronic Deliveries, in particular Articles 9 and 152.
This article provides general information and does not constitute legal advice for a specific matter. The appropriate solution depends on the facts, documents and business objective.
Summary
The main risk is not creating the mailbox but failing to ensure that somebody identifies and acts on legally significant correspondence.