Insurance agent on JDG: 17% or 15% ryczałt, VAT and PKD

An insurance agent running a sole proprietorship in 2026 has a fairly predictable set of formalities: PKD code 66.22.Z, commissions exempt from VAT, and usually no obligation to use a cash register. Most questions concern ryczałt (lump-sum tax on recorded revenue), because the same person may pay 17% or 15% — depending on whether they act personally or with the help of others, and in what role they concluded the contract. Below we explain what each of these answers depends on.

In what role do you act

Before choosing the tax rate, it is worth establishing who you are in the distribution chain. In practice, three models are met:

• agent with their own agency contract with an insurance company (or several — as a multi-agent), entered in the register of agents;
• person performing agency activities for an agent or a multi-agency, without a direct contract with the insurer;
• agency with a team — an entrepreneur who employs or subcontracts policy sales to other people.

These models often overlap. An experienced agent may have their own contracts with insurers and at the same time settle with a multi-agency for policies sold on its behalf. The ryczałt rate depends above all on this.

PKD 2025 code: 66.22.Z and when to add others

In PKD 2025 the basic subclass is 66.22.Z, covering agents and brokers who sell policies and negotiate insurance and reinsurance contracts. This subclass is indicated as the predominant one. Additional codes are useful when the offer goes beyond mere policy sales:

• 66.21.Z — for risk assessment and damage estimation, e.g. handling claims;
• 66.29.Z — for pension and insurance advisory that is not intermediation;
• 66.19.Z — for other activities supporting financial services, e.g. intermediation in financial products other than insurance.

The CEIDG entry alone does not decide the tax, but should be consistent with contracts and invoices. More about choosing codes can be read in the guide how to choose a PKD code.

Ryczałt: 17% or 15%

The Flat-rate Income Tax Act classifies insurance agents as free professions — provided the activity is performed personally. Personal performance means not hiring, under an employment, mandate, specific-task or similar contract, persons who perform activities related to the essence of the profession. Revenue from such a free profession is subject to the 17% rate.

The 15% rate applies to financial and insurance services from PKWiU section K that are not provided within a free profession. In practice this is the rate for:

• an agent who engaged employees or contractors in sales;
• a person performing agency activities for another agent, if they do not fit the definition of a free profession — the definition lists insurance agents, so what matters is the content of contracts and the nature of cooperation;
• other services from section K, e.g. part of support services.

An assistant who only arranges meetings and conducts correspondence does not perform agency activities. It is different when a co-worker independently sells policies — then the condition of personal performance ceases to be met.

Example: a rate change during growth

In 2026 an agent earns PLN 14,000 of commission per month, working alone — ryczałt is 14,000 × 17% = PLN 2,380. From July she subcontracts policy sales to two people under mandate contracts. From then on her revenue ceases to meet the free-profession definition and is subject to the 15% rate. With high co-worker costs it is worth, in passing, recalculating whether ryczałt is still worthwhile compared with the flat tax, in which costs reduce the base.

When choosing the form of taxation, the health contribution must also be taken into account. Under ryczałt it depends on annual revenue and in 2026 is PLN 498.35 per month (revenue up to PLN 60,000), PLN 830.58 (from PLN 60,000 to PLN 300,000) or PLN 1,495.04 (above PLN 300,000). The agent in the example, with annual commissions of about PLN 168,000, pays PLN 830.58 per month, regardless of how much she spends on running the agency.

If one business includes revenue from different roles, the revenue records must allow each commission to be assigned to a rate — settlements with insurers and with the multi-agency are best booked separately. The general rules are described in the article on ryczałt and its rates.

VAT: commission exemption and its consequences

The exemption for insurance and reinsurance services and for intermediation in their provision is set out in item 37 of art. 43(1) of the VAT Act. The agent's commission is therefore invoiced without VAT, citing this basis of exemption. An agent providing only such services does not have to register as an active VAT taxpayer.

The exemption has two consequences that are easy to forget:

1. No VAT deduction on purchases. The tax from invoices for a car, phone or office becomes a cost for the agent, because there is no output VAT from which it could be deducted.
2. Caution when combining services. When an agent starts to provide taxed services (e.g. sales training for other companies, rental, marketing services), they must watch the turnover-based VAT exemption limit — in 2026 PLN 240,000. The Act excludes from this limit most revenue exempt under art. 43(1), but explicitly reserves an exception for insurance and reinsurance services, unless they are of an ancillary nature. In practice, it must therefore be checked whether and to what extent commissions count towards the limit.

Cash register

The Regulation on cash register exemptions (applied until the end of 2027) exempts financial and insurance services from PKWiU groups 64–66 — regardless of turnover and whether the client is a company or a private individual. The obligation may arise when the agent starts to sell other services or goods to private individuals for which the exemption does not apply. The details of the rules are described in the guide who needs a cash register.

Checklist before the start

1. Establishing the role: own agency contract, cooperation with a multi-agency or both models.
2. Registration in CEIDG with code 66.22.Z and additional codes only for truly planned services.
3. Choice of the form of taxation — for ryczałt, decision whether the work will be performed personally.
4. ZUS registration, including a decision on start-up relief or a preferential contribution base.
5. Invoice template without VAT with the basis of exemption from art. 43(1)(37).
6. Separate records of commissions from different sources, if two ryczałt rates are in play.

How Good Balance can help

We help agents and multi-agencies choose the form of taxation, assign commissions to the correct rates and correctly invoice VAT-exempt services. Sole proprietorship support is described on the page registration and running of JDG.