What to do if your supplier is missing from the VAT white list?

You have an invoice for PLN 18,450 from a Polish supplier. Before paying, you look up their tax ID in the Ministry of Finance register and the bank account printed on the invoice is not there. Or the supplier is missing entirely.

If you hit "pay" anyway, two things can happen on the day you place the transfer: the expense stops counting as a tax-deductible cost, and you can become jointly liable for the supplier's VAT on that deal. Both consequences are triggered by the transfer order, not by the invoice. So the cheapest fix comes before payment, and there is still a fix after it.

Note: the author runs a Polish invoicing and KSeF SaaS and is not an accountant or tax adviser. Legal points below are linked to sources; confirm anything specific to your case with a Polish tax adviser.

What "not on the white list" actually means

The "white list" is the official VAT taxpayer register run by Poland's tax administration. It lists VAT-registered businesses and the bank accounts they have declared. Three different problems hide behind the same phrase.

The supplier is listed, the bank account is not. This is the common one: a new bank, a private account typed onto the invoice, or a swapped account number. It is the case that triggers the penalties described below.

The supplier is not VAT-registered, or was struck off the register. Now the question is not where to send the money but whether the invoice carries valid VAT you may deduct.

The supplier is exempt from VAT and never registered. According to PITax, the white list does not cover entities exempt because they stay under the PLN 200,000 turnover threshold, so the account rule does not apply to them.

The rule: PLN 15,000 and two penalties

The white-list obligation applies when three things coincide: you pay a Polish VAT taxpayer, the transaction value exceeds PLN 15,000 gross (or the foreign-currency equivalent), and you pay by bank transfer. The test is the value of the transaction, not of a single transfer, so splitting one invoice into three payments does not help.

If you pay to an account outside the register, there are two consequences:

• Lost cost deduction. Under Article 22p of the Personal Income Tax Act (and Article 15d of the Corporate Income Tax Act for companies), the part paid to a non-listed account is not a tax-deductible cost.

• Joint liability for VAT. Under Article 117ba of the Tax Ordinance, you answer together with the supplier for the VAT on that specific transaction if the supplier fails to account for it. It does not extend to the supplier's other tax arrears.

A worked example: you buy a service for PLN 15,000 net plus PLN 3,450 VAT, PLN 18,450 gross, and pay to the supplier's private account. Without further steps you cannot deduct PLN 15,000 as a cost, and you are exposed for the PLN 3,450 of VAT.

Before you pay: three options

Check the account on the transfer date. What counts is the register as it stands on the day you order the transfer. Keep a dated screenshot or printout of the check.

Ask the supplier to fix it. A business can declare its company account to the register. Private accounts cannot be declared, so for invoices above PLN 15,000 ask for a business account.

Pay by split payment. Paying through Poland's split payment mechanism releases you from the joint liability, and according to bizky.ai from the lost-deduction rule too. The VAT part lands on the supplier's VAT account instead of their current account, which they may not love, but it closes the issue.

Already paid to a non-listed account? File ZAW-NR within 7 days

You can still protect yourself by filing form ZAW-NR, a notice of payment to an account not on the list.

1. Deadline: 7 days from the day you ordered the transfer (Article 117ba § 3(2)). Weekends and holidays count, and the deadline cannot be reinstated.

2. File with your own tax office, not the supplier's, online through the e-Tax Office portal or on paper. This has been the rule since 1 July 2020.

3. Tick the legal bases: item 7 (VAT, release from joint liability) and item 8 (income tax, keeping the cost deduction) if you want both covered. The form is set by a Ministry of Finance regulation.

4. Provide the account number you paid, the amount and the date of the transfer order.

Do not file ZAW-NR preventively with every transfer. Commentators note that this is not what the mechanism is for.

Can you still deduct the VAT?

Missing from the register is not, by itself, listed as a ground for denying input VAT in Article 88(3a) of the VAT Act. That list covers things like invoices from non-existent or unauthorised issuers and invoices that do not reflect a real transaction.

In practice, tax offices look at whether you exercised due diligence, and checking the supplier in the register is one of the usual steps. Case law on invoices from unregistered or struck-off suppliers is mixed, so for larger amounts ask an adviser before you deduct.

Where KSeF fits in

KSeF is Poland's national e-invoicing system, and purchase invoices now arrive through it. That removes the old habit of retyping bank details from a PDF, but it also means nobody pauses to check the supplier. The transition period without KSeF penalties ends on 31 December 2026, and penalties apply from 2027, so it pays to tidy up your payables process now.

In Biurko, the supplier's VAT status is checked against the register and refreshed, and purchase invoices from KSeF land in a single list. You still decide on payment and any ZAW-NR, but you no longer have to remember to look up every tax ID by hand.

Checklist before paying an invoice above PLN 15,000

• Look up the supplier's tax ID and account in the register on the day you order the transfer.

• Save proof of the check with its date.

• Account missing: ask for a company account or for the supplier to declare it.

• Cannot wait: pay by split payment.

• Already paid to a wrong account: file ZAW-NR within 7 days.

• Paying in instalments: count the whole transaction, not each transfer.

• Supplier unregistered or struck off: review the VAT deduction risk with an adviser.

Summary

An invoice from a supplier outside the white list is only a problem if you send more than PLN 15,000 to the wrong account. The penalties are two (cost and joint VAT liability) and the remedies are two as well: split payment before the transfer, or ZAW-NR within seven days after it.

If you want KSeF purchase invoices, supplier VAT status and VAT registers in one place, try Biurko free for 14 days.

FAQ

Can I pay an invoice to an account that is not on the Polish VAT white list? Yes, but above PLN 15,000 gross you lose the cost deduction and risk joint liability for the supplier's VAT. You avoid both by paying through split payment or by filing ZAW-NR with your tax office within 7 days of the transfer order.

How long do I have to file ZAW-NR? Seven days from the day you ordered the transfer, counting weekends and holidays. The deadline cannot be reinstated. File with your own tax office, most easily online through the e-Tax Office portal.

Does the white list apply to invoices under PLN 15,000? No. The penalties in Article 22p of the PIT Act and Article 117ba of the Tax Ordinance apply only to transactions above PLN 15,000 gross, or the equivalent in a foreign currency.

What if my supplier only has a private bank account? Private accounts cannot be declared to the register. For an invoice above PLN 15,000 from a VAT-registered business, ask for a company account or pay by split payment.

Does a missing white-list entry block input VAT deduction? Not directly: Article 88(3a) of the VAT Act does not list it as a ground. But tax offices examine due diligence and whether the transaction was real, so get advice on higher-value invoices.