# Poland’s VAT white list: check an account before paying
Source: https://norman.finance/pl/en/blog/poland-vat-white-list-bank-account-check
Author: Norman
Published: 2026-11-15
Updated: 2026-11-15

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**Before transferring money, check the recipient’s exact bank account on Poland’s VAT white list for the date you order the payment.** Compare the supplier’s NIP, legal name and account number, then save the result with its query identifier. An “active VAT taxpayer” status alone does not confirm that the account copied from an invoice is the right one.

This guide is for running payments in a Polish limited liability company, or **sp. z o.o.** The discussion of deductible costs concerns standard corporate income tax, CIT. Companies using Estonian CIT should confirm their treatment with their accountant. **Sources checked: 15 November 2026.** The current rules and the change taking effect in 2027 are explained separately below.

## What is the VAT white list, and where is it?

The “white list”, called **biała lista VAT**, is the VAT taxpayer register maintained by the head of Poland’s National Revenue Administration, KAS. It shows business details, VAT status and reported settlement accounts. It checks registration data; it does not establish that a service was delivered, that a business is solvent or that an email is genuine.

Use the [official Ministry of Finance search tool](https://wykazpodatnikowvat.mf.gov.pl/). The modernised service launched on **15 October 2026**, as confirmed in the [ministry’s launch notice](https://podatki.gov.pl/aktualnosci/wdrozenie-zmodernizowanego-wykazu-podatnikow-vat-13102026). Update an old browser bookmark to the current address.

You can search by NIP, REGON, business name or account number. NIP is the Polish tax identification number; REGON is a business statistical identifier. For a payment, start with the invoice’s NIP and then check the account you will actually enter in your bank. A trading name alone is not enough when several businesses have similar names.

## How do you check an account before a transfer?

1. **Gather the documents.** Open the invoice, order or contract and the payment instructions. Check whether a later message changed the bank account.
2. **Confirm the supplier’s identity.** Compare the NIP and full legal name. For a company, its KRS registration number is also useful. Do not substitute an intermediary’s tax number without understanding why that entity receives the money.
3. **Select the relevant date.** The account is assessed for the day the transfer is ordered. If you prepare a payment on Friday but order it on Monday, check Monday’s position. For a future-dated payment, confirm which date the bank records as the order date.
4. **Compare the complete account number.** Check the account in the prepared transfer, rather than any account shown under the supplier’s NIP. If there are several accounts, the result must cover the one you use.
5. **Keep the evidence.** Save the result, check date and query identifier. [KAS explains that the identifier](https://www.gov.pl/web/kas/pytania-i-odpowiedzi) can establish that the check was performed and can be retained electronically.
6. **Approve the payment after the check.** The approver should have the invoice, amount, recipient, bank account and verification result. Resolve discrepancies before authorising the transfer.

If an email changes the account, confirm the instruction through a previously known contact channel. A reply in the same email thread is not an independent check. This is a practical payment control alongside the tax assessment of the account.

## Does PLN 15,000 apply to each transfer or the transaction?

[Article 19 of Poland’s Entrepreneurs’ Law](https://eli.gov.pl/api/acts/DU/2026/1484/text.pdf) covers a transaction between businesses whose total value **exceeds PLN 15,000**, regardless of the number of payments. Compare the gross transaction value, including VAT. An advance and a later balance do not create separate limits.

For example, a company orders a service worth **PLN 24,600 gross** from an active VAT taxpayer and pays two instalments of **PLN 12,300**. Each transfer is below PLN 15,000, but the transaction exceeds the threshold. Assess the account for both payment orders, using their respective dates. This is an illustrative example, not a Norman customer story.

A transaction of exactly PLN 15,000 does not exceed the Article 19 threshold. Your company can nevertheless choose to check accounts for smaller payments too. Distinguish that internal policy from the statutory threshold and from the separate conditions for mandatory split payment.

## What if the bank account is missing from the register?

First check the digits, NIP and selected date. Ask the supplier to explain the result and confirm the correct payment account. A missing account may reflect use of a personal account or incomplete registration data. Virtual accounts, factoring arrangements and payments through intermediaries need the appropriate verification and exception checks with your accountant.

Under the 2026 rules, paying an invoice from an active VAT taxpayer to an unlisted account, where the underlying transaction exceeds the threshold, can exclude the corresponding expense from deductible costs. This follows from [Article 15d of the CIT Act](https://eli.gov.pl/api/acts/DU/2026/554/text/U/D20260554Lj.pdf). There is also a separate risk of joint and several liability for the supplier’s VAT arrears attributable to the supply.

The legislation provides exceptions. For a typical domestic transaction, discuss these two options with your accountant:

- **ZAW-NR:** a notification on the first payment to that account, filed within seven days of ordering the transfer with the head of the tax office responsible for the payer.
- **MPP:** correctly using the split payment mechanism, where that mechanism can be used for the payment.

The relevant protections are in Article 15d(4) of the CIT Act and [Article 117ba § 3 of the Tax Ordinance](https://eli.gov.pl/api/acts/DU/2026/622/text/U/D20260622Lj.pdf). If money has already been sent, give your accountant the order date, invoice, amount and account details immediately. Do not assume that the account appearing in the register later automatically fixes the earlier payment.

## Is a settlement account the same as a VAT account?

No. Check the supplier’s settlement account in the register, rather than the separate VAT account used in split payment. The [ministry’s MPP guidance](https://www.gov.pl/attachment/36857f08-376f-4a11-ac2a-136ee1ca8957) explains how the bank separates the net amount and VAT. You do not make two ordinary transfers to two different accounts yourself.

Complete the required fields in the bank’s MPP form using the invoice and review them before approval. Typing “split payment” into an ordinary transfer’s reference does not use the mechanism. Also establish whether that particular invoice requires mandatory MPP. A positive white-list result does not answer that separate question.

## What changes from 2027?

The [Act of 18 September 2026, Journal of Laws item 1371](https://eli.gov.pl/api/acts/DU/2026/1371/text/T/D20261371L.pdf), removes the PIT/CIT cost exclusion solely for paying an unlisted account from **1 January 2027**. The restriction on costs for payments made without a payment account in Article 19 transactions remains.

**Check the invoice date:** Article 3(2) preserves the old rules for payments arising from invoices issued before 1 January 2027. A December 2026 invoice paid in January 2027 still falls under the previous provisions. The amendment does not remove joint VAT liability under Article 117ba or obligations imposed by the VAT Act’s MPP rules. Keep your account-checking procedure in place.

## How can an accountant and AI support the process?

Assign responsibility for preparing payments, checking accounts and authorising transfers. A useful control log records the invoice number, NIP, amount, account, order date, query identifier, result and approver. This is a suggested record layout, not a prescribed statutory form.

[Norman can fill in business details from a NIP](/pl/en/help-center/clients-and-products), including the name, address and VAT status from available registers. The [AI assistant](/pl/en/ai-bookkeeping) helps you work with company invoices and transactions. Start with a question about a specific invoice and compare the response with the underlying document.

Filling in a business profile is not proof that its bank account was checked for the transfer date. Retain that evidence from the official register. AI helps prepare information; you and your accountant check sources and any exceptions. An authorised person approves the bank transfer. After payment, link the confirmation to the invoice. If the remaining amount is disputed, use a [balance confirmation with the supplier](/pl/en/blog/balance-confirmation-poland-how-to-reply) to investigate it.