December 11, 2025

[#2] Debt to ZUS is rising while tax arrears are falling? We explain the paradox that shows where companies look for a "last resort"

[#2] Debt to ZUS is rising while tax arrears are falling? We explain the paradox that shows where companies look for a "last resort"

While companies' debt to ZUS keeps hitting new records, the National Revenue Administration reports a decrease in tax arrears. Does this mean that suddenly it is easier for entrepreneurs to pay taxes and harder to pay contributions? Quite the opposite. This fascinating divergence in the data is the key to understanding the desperate choices Polish companies are forced to make as they fight to stay liquid. We analyze the hard numbers and explain why ZUS has become an unintended "bank" for many businesses.

In business, very little happens by accident. When two key public debt indicators move in completely opposite directions, we have to ask: why?

On one side we have ZUS, where the debt of active payers has exceeded PLN 21 billion and is growing at a rate of 7-8 percent per year. On the other, we have tax data showing a completely different, surprising picture.

The Tax Office is regaining ground, ZUS is losing it

The latest data sheds light on this contrast. In the most recent reporting period, the National Revenue Administration (KAS) recorded a decline in total tax arrears from PLN 97.2 billion to PLN 94.4 billion. This is a significant trend reversal, especially if we recall the dynamic growth in tax debt during the pandemic years.

What is more, the effectiveness of tax enforcement is increasing. This ratio has jumped by nearly 3 percentage points, reaching over 46.5 percent. Put simply, tax offices are becoming faster and more effective at collecting what they are owed.

How does this compare to the situation at ZUS, where both the total amount of debt and the average debt per company (PLN 33,700) are steadily rising?

Survival strategy - who gets paid first?

This discrepancy does not stem from the fact that companies "prefer" to pay taxes and "dislike" paying contributions. It is the result of cold calculation in an empty cash account scenario.

When an entrepreneur loses liquidity and has enough funds to cover only part of their obligations, they must carry out brutal prioritization. In this ranking, the Tax Office usually beats ZUS. Why?

  • Fear of the Fiscal Penal Code: Liability for unpaid taxes, especially VAT, is perceived as much more severe and immediate. Entrepreneurs are afraid of criminal and fiscal charges.

  • Speed of account seizure: KAS enforcement tools are extremely effective. A bank account freeze by the Tax Office can happen very quickly, paralyzing the company's operations from one day to the next.

  • The illusion of a "soft" ZUS: ZUS is often perceived as a more "structured" creditor. The availability of installment arrangements and a seemingly slower enforcement machine make contributions the liability that "can wait".

In this way, ZUS becomes a "lender of last resort" for Polish companies. Unable to get a loan from a bank, entrepreneurs "borrow" money from the state by not paying contributions, in order to put out what they see as more urgent fires, including tax arrears.

The "cheap credit" trap in ZUS

Treating ZUS as a liquidity buffer is like walking on thin ice. What looks like a short term rescue is in fact one of the most expensive and riskiest forms of financing.

Why?

  • Loss of benefits: A single day of delay (or an underpayment of just a few grosz) can deprive you of the right to sickness benefits. If you fall ill, you are left without income.

  • Exclusion from the financial market: ZUS arrears are a red flag for banks and leasing companies. As long as you appear in debtor registers, the path to affordable growth financing, a car lease, or a new machine is effectively closed.

The snowball of interest:ZUS debt almost never stands still. Interest and enforcement costs mean that the amount to be repaid grows faster than the company can generate profit to cover it.

👉 Also read: How to check your ZUS and tax arrears online

You do not have to choose the "lesser evil"

The paradox of rising ZUS debt and falling tax debt shows that Polish entrepreneurs can be very disciplined when they feel under pressure. The problem is not a lack of willingness to pay, but a lack of liquidity.

Payment gridlocks and rising costs force companies to juggle obligations. But instead of risking loss of insurance and a debtor registry entry, it is worth looking for solutions that address the root cause rather than just pushing the problem into the future.

External financing - such as a loan to repay public law liabilities - allows you to "reset" your accounts with the authorities. As a result, you regain a clean slate, restore your entitlement to benefits and, most importantly, you no longer have to choose between legal security (taxes) and social security (ZUS).

Data sources used in the analysis

  • Periodic reports of the Social Insurance Institution (ZUS) on the financial situation of the Social Insurance Fund (2023-2025).

  • Activity reports of the National Revenue Administration (KAS) for 2024-2025.
  • Supreme Audit Office (NIK) report on the collection of social insurance contributions.

Supreme Audit Office (NIK) report on the collection of social insurance contrib

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