Poland's VAT white list in 2026 — the penalties are being repealed, but not until 2027

The white list of VAT taxpayers (biała lista podatników VAT) is a public register maintained by the Head of Poland’s National Revenue Administration, where you can check a counterparty’s VAT status and their business bank accounts. If you pay an invoice above PLN 15,000 into an account that is not on the list, you lose the right to treat that payment as a tax-deductible cost and you become jointly liable for your supplier’s VAT. That is exactly what is now changing: on 21 July 2026 the Council of Ministers adopted a bill repealing the cost penalty, and its first reading in the Sejm took place on 30 July. The point that matters for your business: the bill is not law yet, and the repeal is scheduled to take effect only on 1 January 2027. Until the end of 2026 the current rules apply in full, with no transition period. Below we explain what the register publishes about your company (including its address), when you have to verify an account, how the ZAW-NR notification rescues a payment, and what will genuinely change in 2027.

This article complements our guide to VAT registration with a virtual office: that one covers the road to active VAT status, this one covers what happens afterwards, once your company starts paying invoices and appears in a public register itself.

In short

• The register publishes your company’s address — for a company, its registered seat; for a sole trader, the address of their fixed place of business, or their home address if they have none
• The threshold is still PLN 15,000 per transaction (art. 19 of the Entrepreneurs’ Law) — the PLN 8,000 figure never entered into force
• Two penalties currently run in parallel — loss of the tax-deductible cost (art. 22p PIT / art. 15d CIT) and joint liability for the seller’s VAT (art. 117ba of the Tax Ordinance)
• A government bill (Sejm print no. 2837) repeals the cost penalty from 1 January 2027 — first reading held on 30 July 2026, but it is still not law
• Joint liability stays, as does the 30% VAT penalty for skipping mandatory split payment
• ZAW-NR saves the situation, but you only have 7 days from the day you order the transfer — filed with the buyer’s tax office, not the seller’s
• A personal current account will never appear on the list — the most common trap when paying sole traders

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What the white list is and who runs it

The white list — formally the “register of entities registered as VAT taxpayers, unregistered, and deleted from and restored to the VAT register” — operates under art. 96b of the VAT Act (consolidated text: Journal of Laws 2025, item 775). It is maintained by the Head of the National Revenue Administration (Szef KAS), not by the Ministry of Finance itself.

You will find the register at podatki-arch.mf.gov.pl/wykaz-podatnikow-vat-wyszukiwarka — you can also reach it via podatki.gov.pl, which redirects there. If an older guide points you to wl.mf.gov.pl, ignore it: that domain no longer resolves.

Three features of the register matter most in practice:

• It updates once per business day. An account reported today will not appear in the register the same minute — a real problem when paying newly incorporated companies.
• It holds five years of history. You can check a counterparty’s status “as at a chosen date, falling no earlier than within the 5 years preceding” the current year. This is decisive during an audit: what counts is the state of the register on the day you ordered the transfer, not on the day of the audit.
• It is searchable by four parameters — NIP (tax ID), REGON, bank account number, and entity name (minimum 5 characters).

There is also a free API at wl-api.mf.gov.pl, which lets you query the register automatically by NIP, REGON or account number, and to confirm in a single request whether a given account belongs to a given NIP. Bulk queries handle up to 30 entities at a time. If your accounting office uses modern software, this verification most likely happens automatically on every transfer — worth confirming rather than assuming.

What the register publishes about your company — including the address

This is the question our clients ask most often, so let us answer it directly: the white list is a public register and it publishes your company’s address. The full catalogue of data under art. 96b sec. 3 covers:

The address — which one exactly

The provision distinguishes two situations, and the distinction matters:

• A limited liability company and other legal persons — the address of the registered seat is published (art. 96b sec. 3 point 6). For a company with a virtual office address, the register therefore shows the office address, exactly as the KRS does. There is no difference in treatment.
• A sole proprietorship — the address of the fixed place of business is published, and only “where the entrepreneur has no fixed place of business” is the home address published instead (art. 96b sec. 3 point 7).

For sole traders working from home, this means the home address lands in a public, searchable register — and, through the API, in bulk queries too. Having a business address changes what appears in the register.

Let us be honest about where the limit lies, though: the register mirrors the data reported to CEIDG and the tax office; it is not a place where an address is “set”. Whether a particular address qualifies as a fixed place of business in the legal sense depends on how you actually run the business, and is a separate question worth discussing with your accountant. We are not selling the simple promise that “buying an address makes your home disappear from the registers” — that is not how it works.

When you must check the account — the PLN 15,000 threshold

The verification duty is triggered by a transaction whose single value exceeds PLN 15,000. The basis is art. 19 of the Entrepreneurs’ Law (consolidated text: Journal of Laws 2025, item 1480), which requires business-to-business transactions to be settled through a payment account.

Two misunderstandings still circulating online are worth correcting here:

• The threshold is PLN 15,000, not PLN 8,000. Lowering it to PLN 8,000 was part of the “Polish Deal” package, but it never entered into force — the provision was repealed before it started to apply. If a guide quotes PLN 8,000, it is out of date.
• The basis is art. 19 of the Entrepreneurs’ Law, not “art. 108e of the VAT Act”. Several popular accounting portals repeat this error. If a source gets the legal basis wrong, treat the rest of its content with caution too.

How to apply the threshold in practice:

• What counts is the value of the transaction, not of a single payment. A PLN 30,000 contract paid in three instalments of PLN 10,000 is a transaction above the threshold — every instalment is subject to the rules. Advances and partial payments aggregate into the transaction value.
• The rules apply only to invoices from active VAT taxpayers. Paying into an off-register account of a VAT-exempt business does not trigger the penalties, because such an entity simply is not in the register in that capacity.
• The decisive date is the day the transfer is ordered. That is the day you check in the register and the day that counts during any audit — which is why the five-year history is so useful.

What happens if you pay into an off-register account

Today two independent penalties apply — and their duplication was precisely the argument for deregulation:

The cost penalty has three independent grounds in sec. 1 — worth distinguishing, because only two of them are being repealed:

1. point 1 — payment bypassing a payment account (e.g. cash above the limit)
2. point 2 — payment into an account outside the register
3. point 3 — skipping the mandatory split payment mechanism

Partial payment in cash works proportionately: on a PLN 20,000 transaction of which PLN 5,000 was paid in cash, you lose the cost on that PLN 5,000 only.

New: a government bill repeals the cost penalty from 2027

This is the most important development to know about in the summer of 2026 — and the most common source of confusion, because some commentary describes it as though it were already in force.

The facts as they stand today:

• 21 July 2026 — the Council of Ministers adopted a bill amending the PIT and CIT Acts (prepared by the Ministry of Finance and Economy as deregulation project UDER107)
• 22 July 2026 — the bill reached the Sejm as print no. 2837
• 30 July 2026 — the first reading was held at a sitting of the Sejm

The bill repeals the cost penalty in respect of points 2 and 3 — that is, for payment into an off-register account and for skipping mandatory split payment. Point 1, concerning payments that bypass a payment account, remains in force.

Three caveats that determine what to do today:

1. It is still a bill, not an act. There is no publication in the Journal of Laws. Until it is passed and enters into force, the provisions apply in their current wording.
2. The repeal is scheduled to take effect on 1 January 2027 — the remainder of the amendment 14 days after promulgation. This means every payment made up to 31 December 2026 is subject to today’s rules, even if the act is passed in the autumn.
3. Joint liability stays. The repeal concerns the income tax penalties; joint liability for a counterparty’s VAT arrears under art. 117ba of the Tax Ordinance remains in force in defined cases. The 30% VAT penalty for skipping mandatory split payment (art. 108a sec. 7 of the VAT Act) also stays.

The practical conclusion: do not relax your procedures in 2026. Even once the act is passed, account verification will still be necessary — what changes is the stake, not the need for care.

A second bill: raising the PLN 15,000 threshold to PLN 25,000

A separate private members’ bill (print no. 2806) amending the Entrepreneurs’ Law and the VAT Act is before the Sejm in parallel. It would raise the art. 19 threshold from PLN 15,000 to PLN 25,000 as of 1 January 2027, arguing from cumulative inflation since 2018, when the threshold was set.

The side effect would be significant: the white list verification threshold and the mandatory split payment threshold would rise with it, because both mechanisms refer to the same amount.

The bill reached the Sejm on 16 April 2026 and was referred to a first reading on 15 July 2026 — which, as at the publication date of this article, has not yet been held. It is a private members’ bill, so its prospects are less predictable than those of a government bill. Do not plan your settlements around PLN 25,000 — PLN 15,000 applies today.

Paid into the wrong account? You have 7 days

If the transfer has already gone out, the ZAW-NR notification rescues the situation — and it is the most underrated tool in this whole area. The rules where it is easy to slip up:

• Deadline: 7 days from the day the transfer was ordered. Not 14 days — that figure appears in many out-of-date guides and is wrong.
• Addressee: the head of the tax office competent for you as the payer, i.e. for the buyer. This is the most common mistake in practice — the notification is sent to the seller’s office and produces no effect.
• Once per account. You file the notification “on the first payment” into that account; subsequent transfers to the same account are already covered and do not require repeating it.
• It protects against both penalties — both the loss of the cost and joint liability.

The second route is the split payment mechanism. Paying with split payment releases you from both penalties even where the account is not in the register (art. 15d sec. 4 point 3 of the CIT Act and art. 117bb of the Tax Ordinance). For businesses regularly paying counterparties with untidy data, this is a convenient systemic safeguard.

Note the flip side: skipping split payment where it is mandatory (goods and services listed in Annex 15 to the VAT Act, on transactions above PLN 15,000) is an independent ground for losing the cost, and carries an additional liability of 30% of the VAT amount.

The traps we see most often

• A personal current account never reaches the register. Personal accounts are excluded from the STIR system, so they will not appear on the white list even if your counterparty reported them to the tax office. If a sole trader puts a personal account on an invoice, every payment above PLN 15,000 is a problem — and it cannot be fixed on the seller’s side other than by opening a business account.
• Virtual accounts (sub-accounts) are fine. A payment into a virtual account assigned to a business account that appears in the register is treated as compliant — the search resolves that link. This covers the typical mass-payment arrangements used by telecoms and utilities.
• Cards, pay-by-link, PayPal and PayU fall outside these rules. The statute speaks of a transfer into an account; a card payment is a payment order of a different kind. That does not mean the art. 19 threshold disappears — the requirement to settle non-cash remains.
• Checking a counterparty once is not enough forever. VAT status and account lists change; for transactions above the threshold, verify as at the day the transfer is ordered.
• Keep proof of verification. Save or print the search result with the verification date visible — during an audit, the burden is on you to show that the account was in the register on that day.

Foreign counterparties and foreign accounts

This section matters most to our clients, because a Polish company with a foreign owner usually also pays outside Poland.

The carve-out for cross-border transactions (art. 15d sec. 4 point 4 of the CIT Act and art. 117ba § 3 of the Tax Ordinance) removes the obligation to verify the register for: intra-Community acquisitions of goods, imports of goods, imports of services, and supplies settled by the buyer under the reverse charge. Paying a German service provider into their German account, you do not check the white list.

An important exception that catches people out: a foreign business registered in Poland as an active VAT taxpayer and using a Polish NIP is treated in these transactions as a domestic taxpayer. The carve-out then does not apply, and their account should be in the register. If your supplier issues an invoice with a Polish NIP and Polish VAT — verify the account exactly as you would for any Polish counterparty.

Accounts held with foreign banks without a Polish branch are not covered by STIR, so you will not find them in the register. If you have to pay more than PLN 15,000 to an entity with a Polish NIP into such an account, the correct route is a ZAW-NR within 7 days.

Frequently asked questions (FAQ)

Have the white list penalties already been abolished? No. The Council of Ministers adopted the bill on 21 July 2026 and the first reading in the Sejm was held on 30 July 2026 (print no. 2837), but the bill is not yet law. The repeal of the cost penalty is scheduled to take effect only on 1 January 2027, so all payments up to the end of 2026 remain subject to the current rules.

Once the penalties are repealed, will I no longer have to check counterparties? You will. The repeal concerns only the PIT and CIT penalties. Joint liability for the seller’s VAT arrears (art. 117ba of the Tax Ordinance) stays in force, as does the 30% VAT penalty for skipping mandatory split payment.

What is the threshold — PLN 15,000 or PLN 8,000? PLN 15,000 per transaction. The reduction to PLN 8,000 planned under the “Polish Deal” never entered into force. A separate private members’ bill (print no. 2806) proposes raising the threshold to PLN 25,000 from 2027, but that is only a bill for now.

Is my company’s virtual office address visible on the white list? Yes — the register publishes the registered seat address of every company, whether that is an owned office, a leased one, or an address with mail handling. It is not flagged or marked in any way and has no bearing on VAT status.

I run a sole proprietorship from home. Is my home address public? If you have no fixed place of business, the register publishes your home address. Having a business address changes what appears in the register, but whether a particular address qualifies as a fixed place of business depends on how you actually run the business — worth establishing with your accountant.

What is the deadline for a ZAW-NR and who receives it? Within 7 days from the day the transfer was ordered, to the head of the tax office competent for you as the buyer — not for the seller. It is filed once per account.

Does split payment replace checking the white list? In practice yes, as far as protection from penalties goes: paying with split payment releases you from both the loss of the cost and joint liability, even where the account is not in the register. Bear in mind, though, that where split payment is mandatory, skipping it is a separate infringement.

Do I have to check a foreign supplier’s account? For intra-Community acquisitions of goods, imports of goods, imports of services and reverse charge — no. But if the foreign supplier is registered in Poland as an active VAT taxpayer and invoices with a Polish NIP, you treat them as a domestic counterparty and check.

Is a company card payment above PLN 15,000 a white list problem? The register provisions speak of a transfer into an account, so card payments fall outside their scope. This does not release you from the non-cash settlement requirement under art. 19 of the Entrepreneurs’ Law.

Next steps

If you run a Polish company — particularly one with a foreign owner — put this area in order in the following sequence:

1. Check your own entry in the register. Enter your company’s NIP and verify that the status reads “active” and that all the business accounts into which you accept payments genuinely appear there. An account missing from the register is your clients’ problem — and therefore yours.
2. Set a verification rule for transfers above PLN 15,000 and confirm with your accounting office whether the software checks accounts automatically or whether it has to be done manually.
3. Keep evidence of your checks on larger payments — dated as at the day the transfer was ordered.
4. Do not relax your procedures before the end of 2026. The repeal of the cost penalty is due to apply only from 1 January 2027, and only if the act is passed.
5. If a transfer did go to an off-register account — count 7 days from the day it was ordered and file a ZAW-NR with your own tax office. After the deadline, this route is closed.

At Henry Estates we support foreign founders’ companies end to end — from incorporation, through a Warsaw address with genuine mail handling, to working with accountants and setting up ongoing obligations such as KSeF and counterparty verification. We serve clients in five languages.

Book a consultation with Henry Estates →

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This article is for information purposes only and does not constitute tax or legal advice. The bills described (Sejm prints no. 2837 and 2806) had not been passed as at the publication date and may change in the course of parliamentary work. Specific decisions should be taken after consulting a Polish tax adviser or attorney. Legal status: August 2026.