VAT taxpayer white list in Poland: a complete guide for 2026

The VAT taxpayer white list (biała lista podatników VAT) is a key tool in the day-to-day work of businesses in Poland. It lets you check whether your counterparties are reliable and protects you from negative tax consequences. Since September 2019 businesses have had access to a comprehensive database with information on all registered VAT taxpayers, together with their bank accounts. Every business owner should understand how this system works.

The white list was created to make business transactions safer and to reduce VAT fraud. With access to up-to-date information on your counterparties' VAT status and bank accounts, you can make informed decisions about trading partners and reduce the tax risk connected with payments.

What is the VAT taxpayer white list

The VAT taxpayer white list is an official register kept by the tax administration, containing detailed information about entities registered as VAT taxpayers. It works as a central database that businesses can access at any time to check their counterparties. The list is updated on working days, once a day (Article 96b(8) of the VAT Act), so changes in taxpayers' status, identification data and bank accounts appear in it with some delay. Other dates worth remembering are collected in our calendar of Polish tax deadlines.

The main aim of the white list was to make business transactions more transparent and to let businesses easily check the reliability of potential trading partners. The system is an important part of the fight against tax fraud, especially in VAT, where correctly identifying the counterparty is essential for the right to deduct input VAT.

The system lets you check a taxpayer's status not only for today but also for a chosen day in the past, which is particularly useful when verifying past transactions. You can check data back over the 5 years preceding the year in which the entity is checked (Article 96b(2) of the VAT Act).

What information the VAT taxpayer white list contains

The white list contains a wide range of information needed to check a counterparty thoroughly. The basic identification data include the business name of the entity and, for individuals, the first name and surname of the person running the business. The system also includes the NIP (tax identification number), which is the taxpayer's basic identifier in the tax system.

A particularly important piece of information is the entity's status in the VAT register, which can take different values depending on the taxpayer's situation. The system distinguishes active VAT taxpayers, VAT-exempt taxpayers, entities removed from the register and entities refused registration. The status is key to determining whether the entity can issue VAT invoices and whether working with it may limit your right to deduct input VAT.

The main categories of information available on the white list are:

• Identification data (business name, first name and surname, NIP, REGON (statistical number), KRS (National Court Register) number)
• VAT status (active, exempt, removed)
• Addresses (registered office, place of business, place of residence)
• Information on persons authorised to represent the entity (only for some unregistered or removed entities)
• Dates of registration, removal or reinstatement of registration
• Settlement account numbers confirmed in the STIR system

Address data are another important part of the information in the list. For entities that are not individuals, the system shows the registered office address; for individuals, the address of the permanent place of business or, if there is none, the place of residence. This information lets you check whether the entity actually operates at the address given.

The Act also provides for data on persons authorised to represent the entity (first names and surnames of members of the governing body and their NIP numbers), commercial proxies (prokurent) and partners. Under Article 96b(4) of the VAT Act, however, these data are not shown for entities registered as VAT taxpayers; they appear only for some entities that were not registered or were removed from the register.

The key element of the white list is taxpayers' settlement account numbers that have been reported to the tax office (urząd skarbowy) and confirmed in the STIR system. This information is fundamental for safe payments, because payments to accounts that are not on the white list may have negative tax consequences.

Types of bank accounts and the white list

Different types of bank accounts are subject to different rules in the context of the VAT taxpayer white list. Understanding these differences is key to settling payments correctly and avoiding tax problems. The basic division is between settlement accounts, which are visible in the list, and private accounts, which do not have to be reported.

Virtual accounts are a special category because they are not visible in the VAT taxpayer list themselves. However, payments to these accounts have no negative consequences if the main account to which the virtual account was created is on the white list. This rule makes settlements much easier for companies using modern electronic payment systems.

Accounts held with foreign banks are also not visible in the Polish VAT taxpayer list. If you buy goods or services from a Polish active VAT taxpayer and pay to a foreign bank account, negative tax consequences may arise. Before making such a payment, it is worth consulting a tax adviser or asking the counterparty directly for a Polish account.

Banks' own-business accounts and assignment (factoring) accounts of banks and cooperative savings and credit unions need individual analysis. The tax consequences and the obligation to enter such an account in the list depend on how it is used and on the nature of the taxpayer's business.

There are also special categories of payments that are exempt from the obligation to check the white list. They include payments of seized receivables to the account of a court bailiff or enforcement authority in enforcement proceedings. Similarly, payments made by insurers to third parties handling claims do not have to be checked against the VAT taxpayer list.

For transfer orders with a deferred payment date, standing orders and direct debits, the account's status is checked on the day the payment order is given to the bank, regardless of the actual date of the transaction. The aim of this rule is that the check takes place when the payment decision is made, not when it is executed.

How to update data in the VAT taxpayer white list

Updating data in the VAT taxpayer white list requires businesses to act and to know the relevant procedures. Taxpayers with settlement accounts that are not yet on the list or need updating must take specific steps depending on their legal form.

The update process follows these steps:

1. Identify your legal form - decide whether it is a JDG (sole proprietorship), a company entered in the KRS, a civil-law partnership (spółka cywilna) or another legal form
2. Choose the right form - CEIDG-1, NIP-8, NIP-2 or NIP-7 with the NIP-B annex, depending on the legal form
3. Prepare the documents - collect current data on bank accounts and other information needed for the update
4. Submit the application - complete and send the right form to the competent authority (CEIDG or the tax office)
5. Wait for the update - monitor the white list to confirm that the data have been updated
6. Check the data - verify in the list that all data have been entered correctly

Business owners running a JDG must update their data by filing a CEIDG-1 application in the CEIDG system. This can be done online, which considerably speeds up updating the data in the VAT taxpayer list.

Entities entered in the KRS must inform the competent tax office of their bank accounts using the NIP-8 form. This form is used to report all changes in identification data and bank accounts of businesses entered in the KRS.

Individuals running a business that is not subject to entry in CEIDG must use the NIP-7 form with the NIP-B annex. The NIP-B annex is designed specifically for reporting bank account information and is an integral part of the update application.

Updating data is not a one-off task - taxpayers must keep the competent authorities informed of all changes in their business, including opening new bank accounts or closing existing ones. Failing to do so may cause problems with counterparties' payments and negative tax consequences.

Remember that the taxpayer is responsible for keeping its white list data up to date. The tax authorities are not obliged to remind you to update your data, so you should check yourself that your data in the list match the actual situation.

Sellers' responsibility towards buyers

The white list imposes obligations not only on buyers but also on sellers who accept payments above PLN 15,000. Sellers must make sure their data on the list are up to date and correct; otherwise they expose their counterparties to tax sanctions. This responsibility directly affects the company's credibility on the market.

Sellers should also inform their counterparties of any changes in bank account numbers and of the status of their accounts on the list. A proactive approach to communication can prevent problems and build trust in business relations.

Rules for publishing and removing data from the list

The VAT taxpayer white list follows strict rules on publishing and removing data, which are key to understanding how long information about individual entities stays available. These rules keep the database current while preserving the possibility of checking counterparties historically.

Data of entities that the head of the tax office refused to register as VAT taxpayers or that were removed from the register stay in the list for 5 years from the end of the calendar year in which the refusal or removal took place. This rule allows historical checks of entities that had VAT registration problems in the past. Removal can also happen at the business's own request – we explain how to file the VAT-Z form for deregistering from VAT.

Practical example: If a taxpayer was removed from the VAT register in March 2024, its data will remain on the white list until the end of 2029. This lets other businesses check past transactions with that entity and see what its status was in specific periods.

Information on registered VAT taxpayers, including those whose registration was reinstated, is removed from the list after 5 years from the end of the year in which they were removed from the VAT register (Article 96b(7) of the VAT Act). This means that a taxpayer's data remain available in the system throughout the business's life and for 5 years after it ends.

A special feature of the system is that some data are shown as they stand on the day of the check, regardless of which past day you are checking. This means that if a taxpayer has changed its business name, the list will show the current name even when you check its status for a period when it operated under a different name.

The system lets you check a counterparty's data up to 5 years back, which is particularly useful during tax audits or disputes over past transactions. It lets you reconstruct the situation on any day in that period, which matters a great deal for documenting business processes.

An important function of the system is the ability to check which bank account number a taxpayer had in a given period when it was registered as an active VAT taxpayer. This is particularly useful when verifying past transactions and can help clarify doubts about whether settlements were correct.

Practical aspects of using the white list

Using the VAT taxpayer white list effectively in everyday business requires understanding not only the technical side of the system but also how it is applied in practice. You should develop routine procedures for checking counterparties that are proportionate to the scale and nature of your business.

The basic rule is to carry out a check before starting to work with a new counterparty, especially if the planned transactions will be of significant value. The check should cover not only the VAT status but also whether the identification data and bank accounts given by the counterparty match.

The most important elements of a practical check are:

• Checking the counterparty's current VAT status
• Verifying that the identification data match (NIP, business name, address)
• Confirming that the bank accounts given are on the list
• Checking the history of changes in the taxpayer's status
• Documenting the check with its date and time
• Regularly checking the status of regular counterparties

In long-term business relationships it is worth checking counterparties' status regularly, because their tax situation may change. It is particularly important to monitor the status of key suppliers and customers whose possible VAT registration problems could affect your business.

Pay particular attention to high-value transactions, where the tax risk is greatest. In such cases consider additional ways of checking the counterparty, such as searching other public registers or obtaining references from other business partners.

Practical scenario: A company plans to buy machinery worth PLN 500,000 from a new supplier. In addition to the standard white list check, it is worth looking into the supplier's business history and its financial situation in the debt register, and contacting other customers for references. Such a thorough check helps avoid problems with an unreliable counterparty.

The white list should be treated as one of the tools for assessing a counterparty's reliability, but not the only one. A full assessment should also take into account other aspects, such as the entity's financial situation, the history of cooperation and its reputation in the industry.

Businesses operating internationally should remember that the white list covers only entities registered (or not registered or removed) for VAT purposes in Poland. For transactions with foreign entities you need other verification methods suited to each country.

Checking a counterparty on the white list step by step

Effective checking of counterparties on the white list requires a systematic approach and a set procedure. The process should be introduced as a standard procedure in every business that makes transactions above the PLN 15,000 threshold.

When you need to check a counterparty on the white list

The consequences of paying to an account not on the list arise only when all of the following circumstances occur together:

• Transaction value above PLN 15,000
• Payment to an active VAT taxpayer
• Payment to an account not included in the list
• No ZAW-NR notification filed on time

The checking requirement applies only to transactions with active VAT taxpayers. This means that payments to entities that are not VAT taxpayers or are VAT-exempt are not subject to these restrictions. In practice, however, this means you need to check the counterparty's VAT status before every larger transaction.

Example of a typical mistake: the company ABC checked a counterparty's status when it received the invoice on 15 January, but ordered the payment only on 30 January. In the meantime the counterparty's status changed, which caused tax problems. Correct approach: the check should have been made on 30 January, the day the transfer was ordered.

How to check a VAT counterparty – the procedure

Below is the detailed checking process:

1. Identify the transactions to be checked by looking at the invoice value
2. Collect the counterparty's data: NIP, company name, bank account number
3. Choose the checking method: Ministry of Finance search engine or external software
4. Carry out the check on the day of the planned payment
5. Save the check confirmation or the request identifier
6. Decide on the payment method based on the results of the check
7. If there are problems: contact the counterparty or use the split payment mechanism

If problems with a counterparty are found, the business has several options: it can contact the counterparty to clarify the situation, use the split payment mechanism or prepare to file a ZAW-NR notification. Each of these options has its consequences and should be chosen deliberately.

The white list as a tool for checking VAT taxpayers

Counterparties can be checked on the white list in two main ways, each with its advantages and limitations. The first is to use external accounting software that connects to the application programming interface (API) provided by the Ministry of Finance. These solutions usually offer more functionality and can be integrated with the company's accounting systems.

The available checking methods include:

• The Ministry of Finance online search engine (free of charge)
• Accounting software with API integration (paid)
• A direct connection to the Ministry of Finance API (requires a programmer)
• Services of external providers (subscription)

The second way is to use the search engine provided directly by the Ministry of Finance. This method is free and available to all businesses, but offers fewer automation options. The search engine lets you check a counterparty's status by entering the NIP, part of the name, the REGON or the bank account number.

Whichever method you choose, the check can be made for the current day or for a past date, but not for a future date. This limitation exists because a VAT taxpayer's status can change and the system does not predict future changes. That is why the check should be made as close as possible to the planned payment date.

Checking a bank account on the white list

Situations where the seller has only a private account are particularly problematic. Personal accounts are not included in the list, which means every payment to such an account requires the buyer to file a notification with the tax office. This may discourage potential counterparties from working with the seller.

Consequences of using the system incorrectly

Using the VAT taxpayer white list incorrectly, or ignoring it, can lead to serious tax consequences that may significantly affect your company's finances. A payment to an account that is not on the list does not in itself take away the right to deduct input VAT. The consequences concern payments for transactions worth more than PLN 15,000 (Article 19 of the Entrepreneurs' Law (Prawo przedsiębiorców)) documented by an invoice issued by an active VAT taxpayer: the expense is not a tax-deductible cost (Article 22p(1)(2) of the PIT (personal income tax) Act, Article 15d(1)(2) of the CIT (corporate income tax) Act), and the buyer is jointly and severally liable with the supplier for the supplier's VAT arrears attributable to that transaction (Article 117ba § 1 of the Tax Ordinance Act). In 2026 both consequences apply, but from 1 January 2027 (Act of 18 September 2026, Journal of Laws (Dz.U.) 2026 item 1371) Article 22p(1) of the PIT Act and Article 15d(1) of the CIT Act will cover only a payment made without the use of a payment account – a transfer to an account not on the list will no longer exclude the expense from costs, while the joint and several liability under Article 117ba of the Tax Ordinance Act remains (payments for invoices issued before 1 January 2027 are governed by the previous rules).

You can avoid these consequences by filing a ZAW-NR notification within 7 days of ordering the transfer or by paying under the split payment mechanism (Article 108a of the VAT Act). If the expense has already been treated as a cost, you must reduce your costs or increase your revenue in the month the transfer was ordered (Article 22p(2) of the PIT Act), and a higher tax also means default interest. That is why it is so important to use the available verification tools systematically and correctly. For clients who use our accounting services, we also settle VAT and prepare JPK files.

The main types of consequences are:

• Exclusion of the payment from tax-deductible costs in PIT and CIT
• The need to reduce costs or increase revenue if the expense has already been booked
• Default interest on the overdue income tax
• Joint and several liability for the supplier's VAT attributable to the transaction
• Additional administrative burden connected with explanations
• Risk of detailed tax audits

Businesses should also remember to take particular care with transactions involving entities that are not on the white list or whose status raises doubts. In such situations it is worth consulting a tax adviser or the competent tax office directly.

Situations in which a taxpayer knowingly pays to accounts not on the list, hoping it will not be detected during an audit, are particularly risky. The consequences under Article 22p of the PIT Act, Article 15d of the CIT Act and Article 117ba of the Tax Ordinance Act arise regardless of whether the mistake was intentional.

Example of consequences: A company taxed under the flat 19% tax (podatek liniowy) paid PLN 123,000 gross (PLN 100,000 net + PLN 23,000 VAT) for a machine from an active VAT taxpayer to an account not on the white list and did not file a ZAW-NR notification. The right to deduct the PLN 23,000 of VAT remains, but the company cannot include the expense in its costs (for a fixed asset - the depreciation write-offs on that value), which at 19% tax means a total of PLN 19,000 more income tax and, if arrears arise, default interest as well. If the supplier does not pay the VAT on this transaction, the company is jointly and severally liable for it up to PLN 23,000.

ZAW-NR notification – step-by-step procedure

The legislator has provided a way to avoid losing the right to treat the cost as tax-deductible by filing a notification with the tax office (urząd skarbowy) – the head of the tax office competent for the taxpayer who made the payment (Article 117ba § 3 point 2 of the Tax Ordinance Act, Article 22p(4) point 1 of the PIT Act). The procedure, however, requires quick action and precise completion of all formalities. Filing the notification involves the following steps:

1. Identifying the problem with a payment to an account not on the list
2. Downloading the ZAW-NR form from the tax office website
3. Completing all the required counterparty data
4. Filing the notification within 7 days of the day the transfer was ordered, with the first payment to that account
5. Receiving confirmation that the notification was accepted
6. Keeping the notification and the confirmation in the transaction records

It is worth stressing that a notification filed on time excludes by law both the income tax consequences and joint and several liability – no decision of the tax office is needed. For invoices issued from 1 January 2027, the notification will protect only against joint and several liability for VAT, because the provision excluding from costs a transfer to an account not on the list ceases to apply. The notification does not, however, replace an assessment of the counterparty's reliability. That is why the best strategy is to avoid situations requiring notifications by checking counterparties systematically.

Examples: a late and a timely notification

The first example concerns Mr Marek, a business owner who bought goods worth PLN 16,000 gross from the company ABC. The invoice was issued on 2 January 2026 with a 30-day payment term, and the cost was entered in the KPiR (tax revenue and expense ledger) in January.

Mr Marek ordered the transfer on 17 February 2026, but only after paying did he realise that he had not checked the bank account on the list. When he finally caught up with the check on 3 March 2026, it turned out that the bank account was not on the list, and the 7-day deadline for the notification (until 24 February) had already passed. As a result, Mr Marek lost the right to treat the cost as tax-deductible in the KPiR and had to reduce his costs in February, the month in which the transfer was ordered, which increased his tax base.

The second example concerns Ms Monika, who ran a JDG (sole proprietorship) and on 3 February bought a machine for resale for PLN 20,000 gross. She received an invoice with a 30-day payment term, and the cost was entered in the KPiR in February. Ms Monika ordered the transfer on 27 February 2026, but quickly realised she had not checked the bank account on the list. On the same day she found that the account was not on the list, but she still had 7 days from ordering the transfer to file a notification with the tax office competent for her (as the payer), which allowed her to avoid removing the cost from her books.

These examples show how important it is to check the white list systematically before every payment above the PLN 15,000 threshold. The difference in how quickly Mr Marek and Ms Monika reacted decided whether negative tax consequences could be avoided.

Joint and several liability for VAT

In addition to the income tax consequences, not following the white list rules may lead to joint and several liability for VAT. This sanction is particularly severe, because it means the buyer may be held liable for VAT that the seller has not settled. Joint and several liability arises when the buyer pays to an account not shown in the list and the seller does not pay the VAT on that transaction.

The basic rules of joint and several liability include:

• Limitation to the tax liability from the specific transaction
• Possibility of avoiding it by filing a ZAW-NR notification
• Protection by using the split payment mechanism
• Exclusion for certain types of bank accounts

The split payment mechanism is effective protection against joint and several liability, because the law expressly excludes it for such payments (Article 117ba § 3 point 4 of the Tax Ordinance Act). The VAT amount then goes to the seller's VAT account, from which the funds are intended mainly for tax settlements. This solution is particularly recommended for transactions with new counterparties or where the white list check raises doubts.

Exceptions to joint and several liability also include payments to special bank accounts used for settlements, accounts used to collect receivables and pass them on to the supplier, and accounts kept by a bank as part of its own operations. However, using these exceptions requires the relevant information from the bank or from the invoice issuer.

Doubts and practical problems

The introduction of the white list revealed a number of practical problems that the legislator did not initially foresee. The Ministry of Finance had to issue additional explanations to resolve businesses' most common doubts. The main practical problems include:

• No way of identifying the account for card payments
• Problems with payments through intermediaries (platforms, factoring)
• Doubts about international transactions
• Difficulties checking accounts in foreign currencies
• Problems interpreting the exceptions to the checking requirement

Another problem is payment through an intermediary, for example via payment platforms or factoring companies. In such cases the buyer does not transfer money directly to the seller's account but to the intermediary's account, which then passes the funds on. The Ministry of Finance took the view that such payments are not treated as standard bank transfers within the meaning of the white list rules either.

These explanations show that the white list system has its limits and does not cover all forms of payment. Businesses should be aware of these exceptions, but at the same time be careful with unusual forms of settlement that may raise doubts for the tax authorities.

The future of the VAT taxpayer white list

The VAT taxpayer white list is constantly being modified and improved to make it more functional and useful for businesses. Recent changes made the list available in the CEIDG and Single Point of Contact for Entrepreneurs systems (from 27 November 2025), and from 1 January 2027 the taxpayer's status will be shown as at the chosen day.

One direction of development is greater automation of checks, which makes everyday use of the system easier. The Act expressly provides for automatic checking of the list (Article 96b(2) of the VAT Act), which allows mass checks of counterparties in accounting software.

The directions in which use of the list is developing include:

1. Integration with accounting systems - automatic counterparty checks when invoices are entered
2. Change notifications - automatic alerts about changes in the status of selected counterparties (a feature of third-party software)
3. Automatic checks - the option of integrating the list with your own IT systems
4. Extended search functions - more advanced filters and search options
5. Change history - checking status and accounts on chosen days in the past
6. Data export - the option of downloading data in various formats

The development of blockchain and other innovative technologies may affect how the system works in the future, making it more secure and reliable. International cooperation on checking businesses may also be extended.

Integration with accounting and ERP systems is becoming more and more common, which allows counterparty checks to be automated while accounting documents are being entered. This trend is likely to grow, making the white list even more intuitive and efficient to use.

Frequently asked questions