Since September 2019, Poland keeps a public register — the White List of VAT taxpayers
(Wykaz podatników VAT), run by the head of the
National Revenue Administration. It lists every active and exempt VAT payer and the bank
accounts they've declared.
The obligation that makes it matter: when you pay another business and the one-off
transaction value exceeds 15,000 PLN, the payment has to go to
an account on the White List. (The threshold is a strict over 15,000; the “gross
value” reading is the tax authorities' interpretation, not the literal statute.)
Pay a >15,000 PLN transaction to an account that isn't on the list, and:
- You lose the tax-deductible cost — the amount can't be counted as a cost of earning revenue.
- You become jointly liable — with the seller, with your whole estate — for the VAT on that supply.
There's an escape hatch: file a ZAW-NR notice to your
own tax office (the payer's) within 7 days of ordering the transfer, and both consequences
fall away — once per account since July 2020, not per payment.
The catch at scale. The official API is capped at 100
search queries a day (30 subjects each) or 5,000 subjects a day. Exceed either limit and MF
can block you until midnight — and the block takes down the browser-based checker on
podatki.gov.pl too, so your accountants go dark mid-payment-run. Every check still has to be
provable at audit.
Not legal advice — a developer's summary of public rules. Sources at the foot of the page.