VAT Poland - Whitelist Check for SAP

Our integrated SAP Add-On to comply with the Polish "Biala lista" requirements as from 01/01/2020

Whitelist of VAT Taxpayers in Poland: why you need an automated solution for your SAP system as of January 2020

With our "VAT Poland - Whitelist Check for SAP" solution, our PIKON Competence Center for Legal Requirements have developed an integrated SAP Add-On that makes you compliant with the new Polish legal requirement "Whitelist of VAT Taxpayers" (biała lista). PIKON's "VAT Poland - Whitelist Check for SAP" is an add-on to the SAP standard, which enables you to verify your Polish vendor's data in the database of the NRA and EU, directly from within your SAP ECC or SAP S/4HANA system. As of September 2019, the Polish Ministry of Finance (Ministerstwo Finansów) have imposed amended provisions of "The Act on the Amendment of the Tax on Goods and Services and Certain Other Acts" and introduced the so-called "Whitelist of VAT Taxpayers" (= biała lista) regulation.

The Polish Whitelist of VAT Taxpayers is an online list of VAT payers, which contains important information about entities conducting business activity in Poland. Therefore, it enables taxpayers to quickly and comprehensively verify the registry data of counterparties.

The Polish Whitelist of VAT taxpayers was introduced for two main reasons:

  • It aims to help taxpayers verify their business partners and avoid negative consequences in case of the input of VAT deductions from invoices issued by a non-existent entity or by a company without a VAT payer status
  • The Polish Ministry of Finance seeks to tighten the VAT system

Sanctions for not complying with the Whitelist of VAT Taxpayers regulation in Poland

If you as a buyer transfer money to a bank account that is undisclosed on the Whitelist and your counterparty (your vendor) fails to pay the amount of VAT to the Polish tax office, you as a buyer will be jointly liable with your vendor for the VAT shown on the invoice.

It is important to know that in addition to these VAT sanctions, this Polish regulation also introduces income tax sanctions as of January 2020. In the case of bank transfers, where their value exceeds PLN 15,000.00, you will not be able to include the expense as a tax deductible cost if your payment was made to the bank account of a vendor which is not disclosed on the Whitelist of VAT Taxpayers.

These sanctions will become effective as of January 1, 2020.


How to avoid penalties for not complying with the Polish Whitelist of VAT Taxpayers (Biała Lista) as of January 2020

Until 31 December 2019, payments to the account other than the one specified in the Whitelist for Taxpayers shall not be subjected to sanctions. However, we recommend implementing an automated solution rather sooner than later in your SAP system. According to SAP OSS Note 2822501, SAP will not provide a solution to comply with this legal requirement. Therefore, our own PIKON Competence Center for Legal Requirements have developed our integrated SAP Add-On that does the required check from within your SAP ECC or SAP S/4HANA system. With our solution, you completely comply with this Polish legal requirement and don't need to worry about any sanctions.

Advantages of the PIKON "VAT Poland - Whitelist Check for SAP" solution:

  • Real-time, secured connection with the official Whitelist of VAT Taxpayers from the Polish tax authority
  • Automated check against the Polish Whitelist of VAT Taxpayers
  • Daily block and unblock of accounts payable for payment
  • Easy and fast implementation through a transport file
  • No process adaptions needed
  • You gain time - no manual work is needed
  • Manual check is also possible 
  • Overview of all accounts payable
  • Integrated SAP solution
  • Check results are directly visible within your own SAP system
  • Compatible with both SAP ECC and SAP S/4HANA
  • No additional SAP licenses needed
  • Possible with both SAP Business Partners and with the Accounts Payable Master
  • Avoid penalties

Solution details of our SAP Add-On:

  • On-Premise Installation (both SAP ECC and SAP S/4HANA)
  • SAP GUI-Cockpit - Overview of the performed checks
  • Report for manual verification of the NIP/ REGON and bank account
  • Report for planning job to block payments on accounts payable level and to unblock them
  • Transparent reporting on all checks and changes
  • Customizable reactions to missing whitelist records
  • SAP standard communication technology to connect with the Polish Whitelist


There are no specific pre-requisities for our "VAT Poland - White List Check for SAP" solution. Our SAP Add-On works with both SAP ECC and SAP S/4HANA. 

Also, no additional SAP licenses are needed.

Please fill out the form below to request a web-meeting and/or a quotation about our "VAT Poland - Whitelist Check for SAP" integrated SAP solution:


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