The VAT white list – how to check your suppliers in 2026

The white list (the list of VAT payers) is a public register kept by the Ministry of Finance at podatki.gov.pl/wykaz-vat. It contains data on all active and exempt VAT payers, together with the bank accounts they have declared. It was created in 2019 as a tool for tightening up VAT. Since 2020, a payment of more than PLN 15,000 to an account that is not on the list means losing the right to count the expense as a cost and joint and several liability for VAT.

In 2026 the white list remains one of the key verification duties of every B2B company. This article explains what you check, how to do it efficiently and how to avoid the trap of a transfer to the “wrong” account.

What you will find in the list

For every Polish NIP (tax identification number) the list shows:

• VAT status – active payer, exempt (sales up to PLN 240,000) or struck off
• Company data – name, REGON (statistical business number), address, NIP
• Bank accounts – all accounts declared by the taxpayer in CEIDG (the central register of sole traders) or KRS (the National Court Register)
• VAT registration date and the date of removal (if applicable)
• History of changes – when an account was added or removed, when the VAT status changed

Important: the list shows only declared accounts. If your supplier changed bank and did not update the declaration in CEIDG, the new account is not visible, and a payment to it is treated as a payment to an account outside the list.

The PLN 15,000 limit – per invoice

The obligation to pay to an account from the white list applies to a transaction whose value exceeds PLN 15,000 gross (including VAT). What counts is one transaction per invoice, not the monthly total:

• An invoice for PLN 14,999 gross – the obligation does not apply (but it is still worth checking)
• An invoice for PLN 15,001 gross – the obligation applies
• 5 invoices of PLN 10,000 within a month – does not apply (each one is under PLN 15,000 on its own)
• One invoice for PLN 20,000 paid in 2 instalments of PLN 10,000 – applies (the value of the invoice counts, not the instalments)

The amount also covers cash payments – for an invoice over PLN 15,000 gross, payment in cash is not permitted at all (regardless of the white list).

The consequences of a breach

If you pay more than PLN 15,000 to an account that is not on the list and you do not file a ZAW-NR notice:

1. You cannot count the expense as a tax-deductible cost – you pay higher income tax (PIT/CIT)
2. Joint and several liability for the supplier’s VAT – if the supplier does not pay the VAT from that invoice, the tax authority can collect from you the supplier’s arrears in the tax due on that supply (Article 117ba § 1 of the Tax Ordinance Act)
3. Correction of the annual PIT/CIT return – once it is discovered, you have to correct the return and pay the tax due

ZAW-NR – the rescue after a mistake

If you paid by mistake to an account that is not on the list, you have 7 days from the day you ordered the transfer to file a ZAW-NR notice with your tax office (Article 117ba § 3 point 2 of the Tax Ordinance Act). The notice contains:

• The NIP of your company and of the supplier
• The invoice number and the date of issue
• The amount and the date of the transfer
• The number of the account to which you paid
• An explanation (for example, “the supplier changed account and did not update CEIDG”)

After filing ZAW-NR you still deduct the cost and there is no joint and several liability. The 7-day deadline is rigid – after it, the consequences are irreversible.

How to check in practice

Manual check

Go to wykaz-vat.mf.gov.pl, enter the supplier’s NIP and check:

• Whether it is an active VAT payer
• Whether the account it gave you appears on the list
• Whether the account is active on the day of your payment

Save the result of the check – a screenshot or a printout – in case of an inspection. In a dispute, it is the evidence that you acted in good faith.

Checking through the API

The list provides a public API:

GET https://wl-api.mf.gov.pl/api/search/nip/{NIP}?date={YYYY-MM-DD}

The API returns JSON with the taxpayer’s data – ideal for integration with an ERP system.

Integration with the accounting program (ERP)

Polish accounting programs and business management systems (ERP) have built-in white list verification. The process:

1. You enter the supplier’s details (NIP, account)
2. In the background, the system queries the MF API
3. A red flag appears if the account is not on the list or the taxpayer is not a VAT payer
4. Before the transfer is made, the system checks again (at the moment the payment is ordered)
5. The verification logs are saved in the system’s database

For companies with a large number of suppliers this is the only practical way. Checking 200 invoices a month by hand takes several working hours.

The white list vs. KSeF

KSeF (the national e-invoicing system) and the white list are two different registers. KSeF confirms that an invoice has received a KSeF number. The white list confirms that the supplier is an active VAT payer and that its account has been declared. Both checks are required – KSeF does not replace the white list, because in KSeF you can issue an invoice with a NIP that has lost its VAT payer status in the meantime.

In 2026 most accounting programs do the check on both fronts:

• KSeF asks: “Does this NIP exist in the register, and can I accept the invoice?”
• The white list asks: “Is this NIP a VAT payer, and is the account active?”

What next

Checking counterparties and their bank accounts against the white list is not part of the accounting service – you do it yourself, when you issue the invoice and before every payment. If you want to learn more about VAT obligations, see also JPK_V7, JPK_CIT, JPK_PKPIR.

Sources: wykaz-vat.mf.gov.pl, podatki.gov.pl/biala-lista, Tax Ordinance Act (Article 96b, Article 117ba).