Every company in Poland must have a registered office address listed in CEIDG or the KRS. But do you actually need to rent real office space? Let’s look at what a virtual office is, whether it’s legal, and what to watch out for when choosing an address for registration.
- Using a virtual office as a company’s registered office address is fully legal in Poland, confirmed by a 2014 ruling of the Supreme Administrative Court (NSA); nevertheless, tax authorities can refuse VAT registration if there’s no genuine infrastructure to run a business at the given address, under a later, stricter 2019 NSA ruling (case no. I FSK 1363/17) discussed further in the article.
- The law doesn’t require owning physical space, but it does require a legal title to the given address (a lease, sublease, or service agreement with a virtual office operator).
- For a sole proprietorship (CEIDG): it’s enough to provide a delivery address on the CEIDG-1 form; if you have no fixed place of business, you can disclose only the delivery address in the public register.
- For companies (KRS): the registered office is the locality specified in the articles of association, with the full address disclosed in the register; changing the address within the same locality only requires a management board resolution, while changing the locality requires amending the articles of association.
- A virtual office typically costs PLN 50-300/month, depending on location and service package.
- The main risk is that banks are cautious about “mass” addresses when opening an account, and tax authorities may verify the genuineness of the business (economic substance) when registering for VAT.
- Is a virtual office a legal registered office address
- Requirements for sole proprietorships and companies
- VAT verification and virtual addresses, what the tax office checks
- Virtual office, rental or coworking, cost comparison
- Risks and what to watch out for
- The most common mistakes when choosing a registered office address
- Frequently asked questions
Is a virtual office a legal registered office address
Yes, a virtual office can be a fully legal registered office for a company, both for sole proprietorships and commercial law companies.
The condition is that the address must be genuine, allowing correspondence to be received, the entrepreneur must have the right to use the address (e.g. a lease, sublease, loan-for-use agreement, or office services agreement), and correspondence should actually be collected, the mere presence of an address in the KRS or CEIDG isn’t enough.
Polish law doesn’t prohibit using a virtual office address as a company’s registered office. Both CEIDG and the registry courts accept virtual addresses, provided the above requirements are met.
Requirements for sole proprietorships and companies
| Form of business | Requirement |
| Sole proprietorship (CEIDG) | It’s enough to provide the address on the CEIDG-1 form; if there’s no fixed place of business, the relevant option can be selected |
| Company (KRS) | The address must be reported to the KRS along with a document confirming the right to the premises (e.g. an agreement with a virtual office operator) |
| Changing the address within the same locality | Only a management board resolution is required |
| Changing the locality of the registered office | Requires amending the articles of association (notarial deed or the S24 system) |
VAT verification and virtual addresses, what the tax office checks
The biggest source of doubt is VAT registration at a virtual office address. The legal basis relied on by tax office heads is Article 96(4a) of the VAT Act. Under this provision, the tax office may refuse to register a taxpayer (or remove one from the register), among other reasons, if the data given in the registration application is untrue, the entity doesn’t exist, or, despite documented attempts, there’s no way to contact the taxpayer or their representative. Using a virtual office by itself isn’t listed in the law as an independent ground for refusal, but in practice the system treats it as one of the risk markers, which is confirmed by case law, including a Supreme Administrative Court (NSA) ruling of 13 November 2019 (case no. I FSK 1363/17), under which the “registered office address” for VAT purposes cannot be an address made available to many entities under which they don’t actually carry out any activity or management functions.
In practice, this means a company registered at a virtual office address goes through the same verification as any other, what matters is whether real contact with the taxpayer is possible at that address, whether correspondence is actually collected, and whether the entrepreneur responds to the tax office’s requests. To minimize the risk of refusal or subsequent removal from the VAT register, it’s worth:
- Choosing a virtual office operator that actually receives and forwards correspondence, ideally one listed in the RDST register (register of entities providing services to companies or trusts).
- Extending the agreement with a package of access to physical infrastructure (e.g. a set number of hours of access to a meeting room per month), which helps demonstrate that the address is auditable.
- Designating a contact person for the tax office who, in the event of an inspection, will be able to appear at the registered address with a full set of documents.
- Keeping key corporate documentation (accounting books, register of board resolutions, HR documentation) in a precisely indicated location, e.g. an accounting firm, and reporting that location to the tax office if it’s not physically located at the virtual office address.
- Preparing evidence of genuine business activity (a website, contracts with counterparties, a business plan) that would demonstrate, in the event of an inspection, that the company isn’t a sham entity.
It’s worth stressing that the mere fact of using a virtual office cannot be the sole basis for refusing VAT registration, the authority must show additional circumstances indicating a lack of genuine business operations at the given address. In the case of an unjustified refusal, the taxpayer has the right to call on the head of the tax office to remedy the violation of law, and then to file a complaint with the provincial administrative court.
Virtual office, rental or coworking, cost comparison
| Criterion | Virtual office | Coworking with a registered address | Renting your own premises |
| Monthly cost | PLN 50-300 | PLN 300-800 | from PLN 1,000 upward, depending on city and size |
| Access to physical space | Usually limited, billed separately (meeting rooms by the hour) | Yes, open office space and meeting rooms included in the price | Yes, full, exclusive access |
| Correspondence handling | Yes, included as standard | Usually yes, included as standard | Handled independently |
| Risk during VAT verification | Medium, requires additional documentation | Lower, thanks to visible activity in the space | Lowest |
| Flexibility (scaling, relocation) | Very high | High | Low, tied to a longer-term lease agreement |
For most small and medium-sized companies, and entrepreneurs starting a business in Poland, a virtual office remains the most cost-effective solution, especially at the start, when there’s no need yet for physical office space. As the company grows and hires employees, it’s worth considering a move to coworking space or your own premises.
Risks and what to watch out for
When choosing a virtual office, it’s worth checking that the operator actually receives and processes correspondence, rather than just formally providing an address. Some tax office heads keep lists of so-called “mass addresses” registered to a very large number of entities, which can increase the risk of an inspection, so it’s worth choosing a verified operator registered in the RDST register. When opening a bank account, many banks are cautious about virtual addresses, so it’s worth being prepared to explain your business model and provide additional documents if needed, such as the agreement with the virtual office operator and evidence of business activity. Some types of business may require demonstrating additional space, such as a warehouse or workshop, in which case the virtual office address alone won’t be sufficient as the company’s only location.
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The most common mistakes when choosing a registered office address
1. Choosing the cheapest operator without checking its reliability
Price shouldn’t be the only selection criterion, it’s worth checking reviews of the operator, whether it’s listed in the RDST register, and whether it actually provides correspondence handling rather than just formally providing an address.
2. Missing or incomplete written lease agreement
Registration with the KRS or CEIDG requires a document confirming legal title to the premises, missing such an agreement or having an incomplete one (e.g. no consent to register the office at the given address) can result in refusal of registration or problems during an inspection.
3. Failing to update the delivery address when changing operators
If a company changes its virtual office operator, the address in CEIDG or the KRS must be updated, neglecting this obligation risks failing to receive important official correspondence, including tax decisions, which may become final even without being collected.
4. Treating a virtual address as a substitute for genuine business activity
If the business actually requires a physical presence (e.g. in-store sales, a warehouse, a workshop), a virtual office address as the company’s only location may be challenged by tax authorities as insufficient to demonstrate genuine business operations.
Frequently asked questions
Can I open a bank account with a virtual office address?
Yes, but some banks are cautious about such addresses and may ask for additional explanations or documents regarding the business model.
Can I register for VAT with a virtual office address?
Yes, having a virtual office alone isn’t grounds for denying VAT registration; tax authorities treat it as ordinary business practice. What matters is whether the given address has genuine infrastructure allowing contact and actual business operations; if the address is shared by many entities, none of which actually operates there, the tax office may refuse registration or remove the company from the VAT register, under the 2019 NSA ruling (case no. I FSK 1363/17).
How much does a virtual office cost in Poland?
Usually PLN 50-300 per month, depending on the location and scope of services (correspondence handling, access to meeting rooms, etc.).
Do I need to disclose the full address for a company?
Yes, for companies the full address is disclosed in the KRS register, while for a sole proprietorship, under certain conditions, only the delivery address can be disclosed in the public CEIDG register.
What happens if the tax office refuses VAT registration because of a virtual address?
The company can call on the head of the tax office to remedy the violation of law, and then file a complaint with the provincial administrative court. It’s worth presenting evidence of genuine business activity and the ability to be contacted at the given address.
Does a virtual office operator need to be listed in any register?
Entities providing virtual office services should be listed in the RDST register (register of entities providing services to companies or trusts), which increases the operator’s credibility in the eyes of tax authorities and banks.
See also: What Is CEIDG in Poland? Sole Trader Registration Explained, Free Company Registration in Poland, How the S24 Portal Really Works, What Is Sp. z o.o.? Share Capital, Registration and Liability (2026).
Sources
- Commercial Companies Code of 15 September 2000, the registered seat as a required element of the articles of association
- Tax Ordinance Act of 29 August 1997, verification of the registered address by tax authorities
Author: Valerii Kushnirskyi, in-house legal practitioner at MojaFirma.
This article is not legal advice. The choice of registered office address depends on your business model and plans regarding banking services and VAT registration, so we recommend consulting a specialist before making a decision. Sources: Biurowirtual.pl – can a virtual office be a registered office; Vitan Consulting – registered office address in Poland.
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