The gray economy accounted for 18.1% in 2025. GDP, and the forecast for 2026 is 17.7%, which means the third consecutive year of decline in this share, mainly due to the good economic situation – according to the report of the Institute of Economic Forecasts and Analyzes (IPAG).
Research conducted by the Central Statistical Office shows that the share of the gray zone in the Polish economy in 2020–2023 decreased from 11.9 to 8.3 percent. GDP. In the opinion of the Institute of Economic Forecasts and Analyzes, not all activities of the gray zone are covered by the Central Statistical Office estimates, so IPAG presents higher estimates of the size of the gray zone – in 2020-23 it was an increase from 18.0%. to 18.9 percent, and in 2024 a decrease to 18.5 percent.
The gray economy accounted for 18.1 percent. gross domestic product in 2025, and the forecast for 2026 is 17.7%. This marks the third consecutive year of decline in this share. An important reason for this decline is the continued good economic situation in the next year – wrote the IPAG report.
“Assuming the limited impact of the conflict (in Iran – PAP) on the Polish economy (which is supported, among others, by the reduction in excise duty and the introduced maximum fuel price), the good economic situation should lead to an increase in company turnover and higher profits from business activities. This will naturally encourage entrepreneurs to be more active in the registered and legal part of the economy. 2026 will also be a period of accumulation of investments financed from the subsidy part of the National Reconstruction Plan and a further increase in the inflow of EU funds under the perspective financial 2021-2027. As a result, the demand for the services of smaller enterprises (often as subcontractors) should increase, which will be an incentive for them to abandon their activities in the gray zone. – added.
The weakest dynamics of labor costs in years
IPAG estimates that the expected stable situation on the labor market i the weakest labor cost dynamics in years (increase in minimum wage by 3% compared to 19% in 2024 and 10% in 2025) will encourage companies to operate in the gray zone to a lesser extent than in previous years.
The economy has become highly saturated with non-cash transactions, significantly slowing down and limiting its further development. A natural development barrier has appeared. Regardless of the slowdown in the development of non-cash transactions, its positive impact on reducing the size of the gray economy has ceased, the report wrote.
According to IPAG, the additional expected stability of inflation, taking into account the calming situation in the Middle East, will mean smaller cost fluctuations and less pressure on wage increases for companies, which will partially encourage exit from the gray zone.
In IPAG's opinion, changes in the regulatory environment should also support the legal activities of companies, although not all of them.
Problematic KSeF
“The biggest problems will probably be generated by the National e-Invoice System, which has covered most entrepreneurs since April 1, 2026 (…). The need to use the KSeF may encourage some companies to hide their turnover, which would then mean an increase in the gray zone, even though the main goal of the KSeF is to tighten the tax system. An unfavorable change for entrepreneurs (although to a limited extent) is also the increase in the minimum health insurance contribution paid by persons running a business subject to taxation according to a tax scale or with a tax linear,” it was written.
It was added that a solution beneficial for entrepreneurs is a higher limit for cash PIT, which allows you to settle income tax only after receiving payment from the contractor, and not at the time of providing a service, issuing goods or issuing an invoice, which should discourage entrepreneurs from hiding their income. A higher limit for personal VAT exemption should have a similar effect, which increased from PLN 200,000 in 2026. PLN up to PLN 240 thousand zloty.
The increase in excise tax on cigarettes and alcohol encourages shopping in the gray zone
According to IPAG, a further increase in excise tax on tobacco and spirit products will remain a factor encouraging purchases in the gray zone.
Taking into account that registered sales amounted to 128 million liters in 2024 and 125 million liters in 2025, we estimate that the remaining approximately 40 million liters of 100% alcohol. could have been purchased in the gray market (approximately 17 million liters in 2024 and approximately 23 million liters in 2025). The value of hypothetical excise tax revenues that could be obtained in 2025 alone from the estimated volume of the gray zone, i.e. PLN 230,000. hl of alcohol 100 percent (at the rate of PLN 7,991/1 hl), is approximately PLN 1.8 billion (in 2024 it was approximately PLN 1.3 billion) – it was written.
“In total, in the years 2023-2025, the hypothetical lost revenues from excise duty on spirits amounted to approximately PLN 4.4 billion,” it added.
In turn, the value of the so-called tax gap with the gray zone on the market of illegal cigarettes, IPAG estimates the losses incurred by the state budget in 2025 at almost PLN 2.8 billion (in 2023 it was less than PLN 1.7 billion, and in 2024 approximately PLN 2 billion).
Meanwhile, the value of cigarette smuggling into Poland is estimated by IPAG at approximately PLN 2 billion in 2025.
The value of the gray zone increases illegal production. According to IPAG estimates, the value of counterfeit cigarettes introduced to the Polish market should be estimated at approximately PLN 1.3 billion in 2025.
A gray zone is also developed in the area of drug sales. IPAG estimates that the annual turnover of counterfeit medicines in Poland may amount to approximately PLN 1 million, and deducting the costs of criminals – approximately PLN 200 million – the added value generated, i.e. the hidden contribution to the national GDP, amounts to approximately PLN 800 million. The above estimate, according to IPAG, is the lower limit.
The Institute estimates that the high saturation of the Polish economy with non-cash transactions significantly slows down and limits the further development of the gray zone, but its natural development barrier has also appeared in this area.
“Regardless of the slowdown in the development of non-cash transactions, its positive impact on reducing the size of the gray economy has ceased,” it added.
So how? limit the gray zone?
IPAG points to several lines of government action that could reduce the gray zone.
“Stopping the radical increase in the minimum statutory wage – the resulting situation forces many micro-enterprises to operate in the gray zone, especially in smaller towns. Monitoring the spread of the gray zone on the Internet (…): in the sale of counterfeit medicines, illegal tobacco products, or the sale of alcohol of unknown origin over the Internet. In some of these areas, effective actions require large financial outlays, but it can be a highly profitable investment to prevent health threats, the treatment of which will reduce public health care expenses,” it was written.
IPAG also calls for improving the issuance of administrative decisions (e.g. the illegal extraction of minerals necessary for construction shows that in extreme cases, entities applying for permits (licenses) had to wait months or even years for a decision).
Moreover, IPAG proposes that the law be unified in such a way that there is no doubt which activities in the gray economy constitute a crime and which are misdemeanors.
“The postulate to reduce the number of offenses is important, for example by setting the upper value of offenses at an appropriately low level,” it added. (PAP Business)
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