Poland's Zone Law Expires This Year. The Replacement Is Still a Draft.

The Act on Special Economic Zones that Poland has run since 1994 expires at the end of this year. A Ministry of Finance draft numbered UD391 is the bill that would sort the legal position after that liquidation, and Garrigues, writing on May 14, 2026, said the Council of Ministers was scheduled to adopt it in the second or third quarter of 2026.

The Polish Investment Zone is not waiting on this bill to exist. The Act of May 10, 2018 on the support of new investments already lets a firm take a CIT or PIT exemption anywhere in the country, once it has a decision on support. The 1994 act was kept in force because permits issued under the old special economic zones still had time left on them. Garrigues's point is narrower than a succession story: the old statute has to come off the books, and the draft is also the vehicle for a set of changes inside the nationwide zone that remains.

The change a site officer should read first is the brownfield rule. UD391 would drop the "close links" test that now ties an exemption to a new investment, and would instead exempt all income generated by an existing set of assets, provided the activity on those assets and the activity in the new investment share the same PKWiU code, the Polish Classification of Goods and Services. A pitch written against close links is a pitch written against a test the ministry wants to delete.

The same draft would launch an electronic application platform called e-PSI for support decisions, their amendment and their expiry, require an opinion from the head of the National Tax Administration before a decision is granted, and extend the validity of a support decision to 20 years. None of that is current law. It is the contents of a draft whose adoption date, as of May, still sat in this quarter or the one before it.

The strongest objection is that this is housekeeping. The map already changed in 2018, the Polish Investment Zone already issues the decisions, and the December 31 date has been on the calendar for years. That objection is correct about where a new greenfield can land. It is not correct about a brownfield file, a support decision whose term is still whatever the current decision says, or an application that will have to clear the tax administration and an electronic platform that does not yet exist. A second clock lands on the same day. The EU General Block Exemption Regulation, the legal basis for a large share of this aid, remains in force until December 31, 2026. The European Commission's consultation on its replacement closed on April 23, 2026.

Garrigues dated the Council of Ministers decision to the second or third quarter of 2026. August 13 sits inside the second of those windows. The Act on Special Economic Zones and the current GBER both lapse on December 31, 2026.