A transfer to the account shown on an invoice looks like a routine task. Yet for transactions above PLN 15,000, a single out-of-date account number can cost a business owner the tax deduction and trigger liability for someone else's VAT. The safeguard is the register of VAT taxpayers, commonly called the "white list" (biała lista) — a free electronic database maintained by the Head of the National Revenue Administration (KAS), where you can check both a counterparty's status and the numbers of its business accounts.
What the register of VAT taxpayers contains
The register covers entities registered as active or exempt VAT taxpayers, entities refused registration or removed from the register, and those reinstated to it. Alongside the company name or the individual's first and last name, you will find the NIP tax number, the REGON number, the National Court Register (KRS) number, the address, VAT status, the dates and legal grounds of registration, removal or reinstatement, as well as details of the persons authorised to represent the entity, of commercial proxies and of partners, together with their NIP numbers.
From a practical standpoint, the account numbers are the key element. The register publishes only settlement accounts opened in connection with business activity and named accounts at a cooperative savings and credit union (SKOK) — those previously reported in the identification or update filing. Private personal current accounts (the so-called ROR) are not included. You can look up a counterparty by NIP number, REGON number, company name or part of it, or by the account number itself. The database is updated once a day, on every business day, and historical data covers the five years preceding the year of the query.
The PLN 15,000 threshold and the obligation to pay by transfer
Under Article 19 of the Entrepreneurs' Law (Prawo przedsiębiorców), a payment connected with business activity must go through a payment account where the other party to the transaction is another business and the one-off value of the transaction exceeds PLN 15,000. What counts is the value of the whole transaction, not of a single payment — splitting it into several smaller transfers does not disapply the threshold. In 2026 the threshold remains PLN 15,000; the previously announced reduction to PLN 8,000 has not entered into force.
Above that threshold, however, a transfer alone is not enough. The money must reach an account listed in the register of VAT taxpayers — only then is the payment safe from a tax perspective.
Consequences of paying to an account outside the register
The first sanction concerns costs. An amount paid to an account other than the one listed in the register cannot be treated as a tax-deductible cost. If the cost has already been recognised, it must be reduced, and where that is not possible, revenue must be increased instead. The same applies to a cash payment above the threshold, that is, one made bypassing a payment account.
The second sanction is more serious, because it concerns someone else's liability. By paying to an account outside the register, you become jointly and severally liable with all your assets — together with the seller who is an active VAT taxpayer — for that seller's tax arrears in the portion of VAT proportionally attributable to the transaction documented by the invoice. Where payment is made in instalments, both consequences cover only the amounts that went to the wrong account; instalments paid to an account from the register remain safe.
The date the transfer is ordered is decisive
Whether the account appeared in the register is assessed as at the day the transfer was ordered — not the day your account was debited or the seller's account credited. The check should therefore be carried out immediately before ordering the payment, not when the invoice is received. The search tool displays the date and time of the check, which has evidentiary value. The result can be saved on an electronic data carrier or printed out and filed with the payment documentation.
ZAW-NR and split payment — how to avoid the sanction
If the transfer has already gone to an account outside the register, the ZAW-NR notification remains. It is filed with the head of the tax office competent for the taxpayer making the payment, within 7 days of the day the transfer was ordered. Filing on time preserves the tax deduction and removes the joint and several liability. This is a substantive deadline — once it passes it cannot be reinstated, so the response must be immediate. If further payments go to the same account, the notification does not need to be filed again.
The second route is the split payment mechanism. Paying under this model protects against the consequences described above, because the VAT amount goes to the seller's separate VAT account and the state budget is not exposed to the tax going unpaid. For business owners who regularly settle large invoices, split payment is therefore often a simpler safeguard than checking each payment individually.
How to build the check into everyday operations
Good practice is to check a counterparty at the start of the relationship and whenever the account number on an invoice changes — such a change is often a sign of an attempted fraud. It is worth setting a simple routine in the business: check immediately before ordering the transfer, file the confirmation together with the invoice, and for amounts above PLN 15,000 require an additional approval before the payment is sent. From 1 April 2026 sole traders issue invoices through KSeF, but this does not remove the need to verify the account — the account number given in the e-invoice must also be compared against the register.
If it is your own data in the register that is incorrect — for example the business account is missing or the registration date is wrong — you can file a reasoned request with the head of the tax office to correct or remove that data. A missing business account in the register carries a real risk of losing clients who do not want to expose themselves to sanctions.