14 January 2025

E-Delivery System – obligations, implementation schedule 2025

The e-delivery system came into force on 1st January 2025, intended to revolutionize communication between public entities and between these entities and citizens.

The e-Delivery System. The new regulations introduced by the Act of 5th October 2021 aim to adapt the Polish legal system to international solutions, such as eIDAS, which enable the safe and effective exchange of information in electronic mode.

What is the e-delivery system?

The e-delivery system aims to introduce a general obligation to use electronic delivery boxes. It will be an alternative to traditional registered mail with acknowledgment of receipt while ensuring the same legal force. The commitment to implement has been written down in the law in the form of a schedule – entities, depending on their legal nature, have specified dates within which they must establish an efficient and functioning e-delivery system. Thanks to this system, public entities and persons performing public trust professions will be able to exchange correspondence in electronic form in a safe, fast, and documented manner.

The main assumptions of the e-Delivery program include:

• Ensuring the possibility of using one’s address for electronic deliveries.
• Standardization of the registered electronic delivery service.
• Enabling the legally effective exchange of correspondence.
• Ensuring effective evidence of delivery, which is of significant importance in the context of legal and administrative processes.

Obligations of public and private entities

According to the new regulations, all public entities, as well as some private entities, will be required to:

• Have an electronic delivery box.
• Make an entry in the Database of Electronic Addresses (BAE). This entry will be equivalent to expressing consent to the delivery of correspondence to the indicated electronic address.

In turn, entities subject to entry in the National Court Register, such as entrepreneurs or persons performing professions of public trust (e.g. attorneys, legal advisers, tax advisors), will have to set up separate addresses for e-delivery depending on the public or professional roles they perform.

E-Delivery system, implementation schedule

The implementation of the e-delivery system will take place in stages, and individual groups of entities will have deadlines for meeting the requirements related to e-deliveries:

• Group I (January 1st, 2025)
  Until January 1st, 2025, the obligation to have an electronic delivery box and an entry in the BAE applies to:
  • Public entities, such as public administration bodies, ZUS, KRUS, NFZ, local government units, metropolitan associations, and local government budgetary institutions.
  • Persons performing professions of public trust, i.e. attorneys, legal advisers, tax advisers, notaries, restructuring advisers, patent attorneys.
  • Entities entered in the KRS and CEIDG from January 1st, 2025.

• Group II (April 1st, 2025)
  Until April 1st, 2025, this obligation will apply to entities registered in the KRS before January 1st, 2025.
• Group III (July 1st, 2025)
  Entities registered in CEIDG by December 31st, 2024, will be required to implement e-deliveries if they make any changes to their entry after June 30th, 2025.
• Group IV (October 1st, 2026)
  Entities registered in CEIDG before December 31st, 2024, which did not make any changes to their entry after June 30th, 2025, will be required to implement the e-delivery system by October 1st, 2026.
• Group V (October 1st, 2029)
  The final deadline for implementing the e-delivery system by courts, tribunals, prosecutors, bailiffs, law enforcement agencies, and local government units (LGUs) and their associations, metropolitan associations, and local government budgetary institutions concerning the public hybrid service is October 1st, 2029.

Transitional provisions

According to the provisions of the “minor amendment”, which come into force on 1st January 2025, some of the provisions regarding the indefinite address for electronic deliveries and the creation of an address based on the data of the designated operator will be introduced in stages. These provisions will come into force on March 1st, 2025 (concerning the indefinite address) and on June 1st, 2025 (concerning the creation of an address).

The implementation of the e-delivery system in Poland is a step towards simplifying administrative procedures, saving time, and increasing the efficiency of both public and private entities. Although the obligations related to e-deliveries will be implemented gradually, most entities must meet the requirements related to having an electronic delivery box and entering BAE as early as January 2025. The future of electronic communication in Poland is therefore marked by even greater digitization, as well as ensuring the security of document circulation in the public space.