Poland Split Payment Mechanism: Invoice Requirements Guide

Poland's split payment mechanism (mechanizm podzielonej płatności) obligates buyers to divide B2B invoice payments into two streams when the transaction exceeds PLN 15,000 and covers goods or services listed in Annex 15 of the Polish VAT Act. The net amount is routed to the seller's standard bank account, while the VAT portion is directed to a separate, dedicated VAT account. Failing to comply exposes the buyer to penalties reaching 30% of the invoice's VAT amount.

This guide walks through every compliance element that AP teams, finance professionals, and business owners need when handling Poland MPP invoice requirements:

The three mandatory conditions that must all be met before split payment applies
Full Annex 15 categories detailing which goods and services trigger the obligation, with practical examples
How the PLN 15,000 threshold operates, including its application to mixed invoices containing both Annex 15 and non-Annex 15 items
Invoice annotation requirements sellers must follow and buyers should verify
White List verification, the step-by-step process for confirming a seller's bank account before releasing payment
The penalty framework covering consequences for both buyers and sellers who fall short of compliance
Split payment and KSeF interaction, clarifying how mandatory e-invoicing affects split payment workflows
A practical checklist for determining whether a specific Polish invoice requires split payment

Understanding when the split payment mechanism is mandatory begins with the three conditions that must all be satisfied simultaneously.

What Poland's Split Payment Mechanism Is and When It Applies

Poland's split payment mechanism - known domestically as mechanizm podzielonej płatności (MPP) - fundamentally changes how buyers settle invoices that include VAT. Rather than sending one payment covering the full gross amount, the buyer instructs their bank to split the transfer: the net amount flows to the seller's regular bank account, while the VAT amount is routed to the seller's dedicated VAT account. This dedicated VAT account is automatically established by the bank for every business holding a PLN settlement account. The buyer initiates the split through a special structured payment message within their banking system, and the bank executes both transfers from a single instruction.

Mandatory split payment took effect on November 1, 2019, replacing the domestic reverse charge mechanism that previously applied to goods and services listed in the former Annexes 11 and 14 of the Polish VAT Act. This replacement is a critical distinction that English-language guidance frequently muddles: the domestic reverse charge within Poland was eliminated and absorbed into the split payment regime, but cross-border reverse charge obligations remain fully active. Reverse charge still applies to services received from abroad (import of services) and intra-Community acquisitions of goods. Only the domestic application was retired.

Mechanism	Status	Scope
Domestic reverse charge	Eliminated Nov 2019	Replaced by split payment for Annex 15 items
Cross-border reverse charge	Still active	Import of services, intra-Community acquisitions

The EU authorized Poland to apply mandatory split payment as a derogation from standard VAT Directive rules through an EU Council Implementing Decision. This authorization has been extended, with the current mandate running through February 28, 2028.

Three conditions must all be met simultaneously for split payment to be mandatory:

The transaction is B2B. Split payment obligations do not apply to sales made to consumers (B2C transactions).
The gross invoice total reaches PLN 15,000 or more (or the equivalent in foreign currency, converted at the NBP mid-rate on the business day preceding the invoice date).
The invoice includes at least one item from Annex 15 of the Polish VAT Act, which lists specific categories of goods and services subject to mandatory split payment.

If any one of these three conditions is not met, split payment is not mandatory for that invoice.

The mechanism has proven effective at its primary objective of reducing VAT fraud. According to European Commission data on Poland's split payment impact, after Poland introduced mandatory split payment in November 2019, VAT fraud losses dropped from PLN 5.17 billion in 2018 to PLN 3.53 billion in 2020 - a 31.6% decrease. VAT extortion proceedings fell from 3,507 to 2,973 over the same period. These figures explain why the mechanism has been extended and why Polish tax authorities treat compliance seriously. The approach is gaining traction outside Europe as well — Brazil's 2026 tax reform introduces its own split payment mechanism for the new IBS and CBS taxes, applying the same principle of routing tax amounts to government-controlled accounts at the point of payment.

Beyond mandatory cases, voluntary split payment is available on any domestic invoice, even when none of the three mandatory conditions are met. Buyers who voluntarily use split payment gain certain tax benefits, including protection from joint and several liability for the seller's unpaid VAT. For AP departments processing high volumes of Polish invoices, adopting voluntary split payment as a default practice can reduce compliance risk. Poland's split payment requirements are one component of the country's broader digital tax infrastructure, which also includes KSeF e-invoicing as part of a wider European push toward global e-invoicing mandates and compliance.

Annex 15 coverage is the first of the three mandatory conditions, and the one that requires the most invoice-level scrutiny.

Annex 15 Categories: Which Goods and Services Trigger Split Payment

Annex 15 of the Polish VAT Act contains the definitive list of goods and services that can trigger mandatory split payment. The list is organized around PKWiU classification codes (the Polish Classification of Products and Services), and it covers a broad range of industries. If any line item on a qualifying invoice falls into one of these categories, split payment obligations apply.

The following categories cover the major Annex 15 items. Where relevant, Polish-language terms that commonly appear on invoices are noted in italics, since AP staff processing Polish supplier invoices will need to recognize them.

Construction services (PKWiU Section F). Construction firms encounter this constantly. Virtually all subcontracting falls under this category: concrete pouring, steel erection, plumbing installation (usługi hydrauliczne), electrical wiring, roofing, demolition (rozbiórka), and site preparation. Any invoice from a construction subcontractor billing for on-site labor and materials (usługi budowlane) should be flagged for review.

Steel and steel products. Structural steel beams, reinforcing bars (rebar), steel plates, pipes, and profiles (wyroby stalowe) are all covered. Construction firms, manufacturers, and distributors who regularly purchase steel inputs will see these.

Fuel. Look for line items describing bulk diesel (olej napędowy), LPG, gasoline (benzyna), heating oil, and lubricant supplies (smary). Companies with vehicle fleets, logistics operations, or industrial heating systems will encounter these frequently.

Electronics. Both new and used equipment qualifies, which catches IT procurement teams off guard. Laptops (laptopy), tablets, smartphones (smartfony), gaming consoles, printers, processors, and hard drives all trigger the obligation.

Non-ferrous metals. Gold, silver, platinum, aluminum sheet (blacha aluminiowa), copper wire, zinc ingots, lead, and tin. Manufacturers, jewelers, and businesses purchasing raw metal inputs should flag these line items.

Scrap metal and recyclables. Scrap iron deliveries (złom żelazny), recycled aluminum, and other secondary metal materials fall here.

Automotive parts. Engine components, brake assemblies, transmissions, and body panels (części samochodowe). Fleet operators, repair shops, and automotive distributors should monitor these invoices.

Coal and coal products. Coal deliveries for industrial use (węgiel), coke, and briquettes.

Jewelry and watches containing precious metals. Gold jewelry, platinum watches, and silver accessories (wyroby jubilerskie).

Waste and secondary raw materials. Industrial waste processing services (usługi przetwarzania odpadów), hazardous waste removal, and secondary raw material trading.

Plastics in primary forms. Polyethylene pellets, PVC resin (żywica PVC), polypropylene granules, and other raw plastic feedstocks.

One critical rule that AP teams must understand: even a single line item from any Annex 15 category on an invoice that meets the PLN 15,000 gross threshold triggers mandatory split payment for the entire invoice amount, not just the value of the Annex 15 items. A supplier invoice that is 90% standard office supplies and 10% laptops still requires split payment processing if the total crosses the threshold.

The practical challenge is that identifying Annex 15 items requires examining individual line item descriptions on each invoice. When invoices arrive in Polish with supplier-specific terminology, abbreviations, or non-standard descriptions, this becomes a manual bottleneck for AP teams handling volume. For organizations processing invoices across multiple languages and currencies, automated line item extraction turns this from a per-invoice research task into a structured data matching exercise.

With Annex 15 categories covered, the next question is whether the invoice meets the PLN 15,000 gross threshold.

How the PLN 15,000 Threshold Works

The PLN 15,000 threshold is the second condition that determines whether split payment becomes mandatory. This figure refers to the gross invoice total, meaning the full amount including VAT, not the net value and not the value of individual Annex 15 line items alone. Getting this distinction wrong is one of the most common compliance errors for AP teams processing Polish invoices.

Three worked examples illustrate how the threshold applies in practice.

Example 1: Below the threshold. A Polish supplier issues an invoice for construction services (an Annex 15 category) at PLN 10,000 net plus PLN 2,300 VAT, producing a gross total of PLN 12,300. Despite the services falling under Annex 15, the gross amount sits below PLN 15,000. Split payment is not mandatory here. The buyer can still choose to pay via split payment voluntarily, but there is no legal obligation to do so.

Example 2: Mixed invoice above the threshold. A single invoice contains two line items: PLN 8,000 for office furniture (not listed in Annex 15) and PLN 7,000 for laptop computers (electronics, listed in Annex 15). With 23% VAT applied, the gross total reaches PLN 18,450. Because the invoice exceeds PLN 15,000 gross and contains at least one Annex 15 item, split payment is mandatory for the entire invoice amount. The obligation covers the full PLN 18,450, not just the laptop portion. AP staff cannot split the payment between the furniture and electronics lines to avoid the requirement.

Example 3: Foreign currency invoices. When an invoice is denominated in EUR, USD, GBP, or another foreign currency, the buyer must convert the gross total to PLN to assess the threshold. The conversion uses the average exchange rate published by the National Bank of Poland (NBP) for the last business day preceding the invoice date. If the resulting PLN equivalent exceeds 15,000, the split payment obligation applies. For AP departments receiving invoices from Polish suppliers who bill in euros, this conversion step is a required part of every payment approval workflow.

Beyond these standard scenarios, Polish tax authorities enforce an anti-avoidance rule. If a series of related transactions between the same parties are artificially divided into separate invoices, each kept just below PLN 15,000, the authorities may treat those invoices as a single transaction for split payment purposes. A supplier issuing three PLN 14,000 invoices for a single delivery of electronics on the same day, for instance, would trigger scrutiny and potential reclassification as one PLN 42,000 transaction subject to mandatory split payment.

Advance payment invoices (faktury zaliczkowe) follow the same rules. If an advance payment invoice exceeds PLN 15,000 gross and covers goods or services from Annex 15, the split payment mechanism applies to that advance just as it would to a standard invoice. AP teams should evaluate advance invoices against the threshold at the time of each payment, not only when the final settlement invoice arrives.

When an invoice meets all three conditions, the seller is required to include a specific Polish-language annotation on the invoice itself.

Invoice Annotation Requirements for Mandatory Split Payment

Every invoice that falls under Poland's mandatory split payment regime must carry a specific annotation: mechanizm podzielonej płatności. This requirement comes directly from Article 106e(1)(18a) of the Polish VAT Act, and it applies to all invoices documenting transactions involving Annex 15 goods or services where the gross amount reaches or exceeds PLN 15,000. The MPP annotation is one of dozens of mandatory fields that Polish VAT invoices must contain under Article 106e, alongside seller and buyer identification, tax rates, and transaction dates.

The responsibility for placing this annotation falls on the seller. When issuing an invoice that meets both the Annex 15 category and threshold criteria, the seller must include the exact Polish-language phrase "mechanizm podzielonej płatności" on the document. There is no abbreviated form or equivalent accepted in another language. The annotation appears in Polish regardless of whether the rest of the invoice is issued in English, German, or any other language.

On paper and PDF invoices, the annotation typically appears near the payment terms or at the bottom of the document. In KSeF-issued structured invoices, it is a dedicated XML field that renders in the human-readable output. This creates a practical challenge for non-Polish-speaking AP teams processing invoices from Polish suppliers. Staff reviewing incoming documents need to recognize and locate this specific text string, even when they cannot read Polish. Training AP personnel to identify "mechanizm podzielonej płatności" on invoices, or configuring document processing systems to detect it automatically, prevents compliance gaps from going unnoticed.

A critical point for buyers: the obligation to use split payment is determined by the nature and value of the transaction, not by the presence or absence of the annotation. If a buyer receives an invoice for Annex 15 goods or services above PLN 15,000 and the annotation is missing, the buyer must still route the payment through the split payment mechanism. The seller, however, faces a tax penalty equal to 30% of the VAT amount shown on the invoice for failing to include the required annotation. Buyers who notice the omission should flag it to the supplier while proceeding with compliant payment regardless.

Building annotation verification into a standard invoice validation process and compliance checks catches these issues before payment execution. An AP workflow that checks for the "mechanizm podzielonej płatności" text alongside other validation steps, such as VAT number verification and amount reconciliation, reduces the risk of processing a mandatory split payment invoice through a regular transfer. Automated extraction tools can flag whether the annotation is present or absent on each document, giving AP teams a clear compliance signal without manual review of every Polish-language invoice.

Beyond verifying the invoice itself, buyers must also confirm that the seller's bank account is registered on Poland's White List before releasing payment.

White List Verification: Checking Seller Bank Accounts Before Payment

Paying to the wrong bank account can cost you your entire VAT deduction on that invoice, plus joint liability for the seller's unpaid VAT. Polish tax law requires buyers to verify the seller's bank account against a government registry known as the White List (biała lista podatników VAT) before releasing payment on any invoice worth PLN 15,000 or more. This obligation exists independently of the split payment mechanism, but in practice the same invoices often trigger both requirements.

The White List is a public database of VAT taxpayers maintained by the Head of the National Revenue Administration (Krajowa Administracja Skarbowa, or KAS). It contains verified bank account numbers for every entity registered for Polish VAT. The registry was introduced specifically to combat VAT fraud by giving buyers a reliable way to confirm they are sending funds to a legitimate, tax-authority-verified account.

How to Verify a Seller's Bank Account

The verification process follows five steps that AP teams should build into their standard payment workflow:

Obtain the seller's bank account number from the invoice. This is the account where the seller expects to receive payment. Cross-reference it against any previously stored account details for that supplier.
Access the White List search tool. The official portal is hosted at podatki.gov.pl, the Polish government's tax services website. The search function is free and available without registration.
Search by NIP or bank account number. Enter either the seller's NIP (Numer Identyfikacji Podatkowej, the Polish tax identification number) or paste the bank account number directly. Searching by NIP returns all registered accounts for that taxpayer, which is useful when a supplier uses multiple accounts.
Confirm the account on the invoice matches a listed account. The search results display every bank account number that KAS has on file for that VAT payer. The account printed on the invoice must appear in this list.
Save the verification result and date. Download or screenshot the confirmation page showing the match, the date of the query, and the unique search identifier the portal generates. This documentation is your proof of due diligence if the tax authority later questions the payment.

Consequences of Paying to a Non-Listed Account

Sending PLN 15,000 or more to a bank account that does not appear on the White List carries two penalties for the buyer. First, the buyer loses the right to deduct input VAT from that invoice. For a standard 23% VAT rate on a PLN 50,000 net invoice, that means forfeiting PLN 11,500 in recoverable tax. Second, the buyer assumes joint and several liability for the seller's unpaid VAT obligations, up to the full invoice amount. In effect, the tax authority can hold the buyer responsible for VAT the seller fails to remit.

These consequences apply regardless of whether the buyer acted in good faith. The law treats White List verification as a strict obligation, not a best-efforts standard.

The ZAW-NR Escape Valve

If a buyer discovers after the fact that payment went to an account not on the White List, there is a corrective mechanism. Filing a ZAW-NR notification form with the tax office within 7 days of the transfer date removes both the VAT deduction loss and the joint liability exposure. The form identifies the transaction, the non-listed account, and the circumstances of the payment. Meeting the 7-day deadline is critical; a late filing does not provide the same protection.

AP departments processing Polish invoices at scale should treat White List verification as a mandatory pre-payment checkpoint, not a periodic audit task. When verification fails, the payment should be held until the supplier provides an account that matches the registry or the team confirms the ZAW-NR filing path is viable.

Understanding the financial exposure of getting any of this wrong helps quantify why these verification steps matter.

Penalties for Split Payment Non-Compliance

On a single PLN 24,600 gross invoice, a split payment failure can cost the buyer PLN 1,380 in penalties, and the seller faces the same amount. Both sides carry exposure, and the consequences are distinct depending on what went wrong.

Seller Penalties

When a seller issues an invoice that meets split payment criteria but fails to include the required "mechanizm podzielonej płatności" annotation, the tax authority can impose a penalty of up to 30% of the VAT amount shown on that invoice. This applies regardless of whether the buyer actually used split payment voluntarily.

Beyond the 30% surcharge, repeated or intentional omissions can trigger sanctions under Poland's fiscal penal code (Kodeks karny skarbowy), which carries its own schedule of fines and potential criminal liability for responsible officers.

Buyer Penalties

Buyers face two separate categories of exposure, each with different consequences.

Failure to use split payment when required. If a buyer pays the full invoice amount to the seller's regular bank account instead of routing the VAT portion through the split payment mechanism, the penalty mirrors the seller side: up to 30% of the VAT amount on that invoice.

Payment to an account not on the White List. For invoices of PLN 15,000 or more, paying to a bank account that does not appear on the Ministry of Finance White List triggers two consequences simultaneously. The buyer loses the right to deduct input VAT from that transaction, and the buyer assumes joint and several liability for the seller's unpaid VAT obligations. However, this exposure can be mitigated by filing a ZAW-NR notification to the relevant tax office within 7 days of making the payment.

How Penalties Compound in Practice

These penalties apply per invoice, not per supplier or per period. A concrete example illustrates the scale: on an invoice with PLN 20,000 net and PLN 4,600 VAT at the standard 23% rate, the 30% penalty amounts to PLN 1,380 for a single violation. Both the buyer and the seller could face this PLN 1,380 penalty on the same invoice for their respective failures, meaning one transaction can generate PLN 2,760 in combined penalties.

For AP departments processing dozens or hundreds of Polish invoices monthly, a pattern of non-compliance across multiple invoices compounds this financial exposure rapidly. Ten non-compliant invoices of similar value would represent PLN 13,800 in buyer-side penalties alone, before accounting for any White List violations or lost VAT deductions.

Penalty Summary

Violation	Who is penalized	Consequence
Missing MPP annotation on invoice	Seller	Up to 30% of invoice VAT amount
Failed to use split payment when mandatory	Buyer	Up to 30% of invoice VAT amount
Payment to non-White-List account	Buyer	Loss of VAT deduction + joint liability for seller's unpaid VAT
ZAW-NR filed within 7 days	Buyer	Sanctions removed (escape valve)
ZAW-NR filed late or not at all	Buyer	No mitigation available

Poland's split payment mechanism does not operate in isolation. It runs alongside the country's structured e-invoicing system, KSeF (Krajowy System e-Faktur), and understanding how both systems interact is necessary for maintaining complete compliance across your Polish invoice operations.

Split Payment and KSeF: How Both Systems Interact

Poland's split payment mechanism and its national e-invoicing platform, KSeF (Krajowy System e-Faktur), are separate compliance obligations that operate in parallel. Understanding where they overlap and where they diverge is critical for AP teams processing Polish invoices, particularly as Poland's KSeF e-invoicing requirements move toward full mandatory adoption.

KSeF governs how invoices are issued and transmitted. From 2026, all B2B invoices in Poland must be created and delivered through this centralized system. Split payment, by contrast, governs how invoices are paid. Issuing an invoice through KSeF does not alter split payment obligations, and routing a payment through the split payment mechanism does not change KSeF requirements. When both sets of conditions are met, both apply simultaneously to the same transaction.

Within KSeF, the MPP annotation ("mechanizm podzielonej płatności") is handled as a dedicated field in the FA(3) XML schema that structures every e-invoice on the platform. When a seller issues a qualifying invoice, they flag the split payment field in the structured data rather than manually adding text to a PDF. The annotation then appears in the invoice output that buyers receive. This structured approach reduces the risk of missing or incorrectly formatted MPP markings, though it shifts the compliance burden to correct field mapping during invoice creation.

An additional requirement takes effect on January 1, 2027: payment instructions for invoices issued through KSeF must include the KSeF invoice number as a reference identifier. This rule applies to all invoice payments processed through the banking system, not exclusively to split payment transactions. For AP departments, it introduces another data element that must be captured from each invoice and included in payment files sent to the bank.

In practice, businesses handling Polish invoices must manage two parallel compliance workflows. The first involves verifying KSeF issuance and capturing KSeF reference numbers for payment processing. The second requires checking split payment conditions: whether the invoice includes Annex 15 goods or services, whether the gross amount meets or exceeds the PLN 15,000 threshold, whether the MPP annotation is present, and whether the seller's bank account appears on the White List. The Poland VAT account used for split payment is maintained by each seller's bank as a dedicated sub-account, and split payment transfers operate through standard Polish banking infrastructure without requiring any special KSeF integration.

With split payment rules, KSeF requirements, and White List verification all applying to the same invoices, AP teams need a repeatable process for checking each one.

Determining Whether a Polish Invoice Requires Split Payment

Every Polish invoice that crosses an AP desk requires the same compliance check. The process below gives your team a repeatable, seven-step decision framework that covers the full split payment obligation from initial review through payment execution.

Step 1: Confirm the transaction is B2B. Split payment applies only to transactions between VAT-registered businesses. Sales to individual consumers fall outside the mechanism entirely. Check that both the buyer and seller have active Polish VAT identification numbers (NIP).

Step 2: Check the gross invoice total against the PLN 15,000 threshold. Review the total gross amount on the invoice. If the invoice is denominated in a foreign currency, convert it to PLN using the NBP average exchange rate published for the last business day before the invoice date. A single invoice at or above PLN 15,000 gross meets the monetary condition.

Step 3: Examine line items for Annex 15 goods or services. Review each line item description, product code, and SKU against the Annex 15 categories: construction services, steel and non-ferrous metals, fuel, electronics, scrap, automotive parts, coal, jewelry, waste, and plastics. Even one qualifying line item on an invoice that meets the threshold triggers the obligation for the entire invoice amount.

Step 4: Evaluate all three conditions together. Mandatory split payment applies only when all three conditions are satisfied simultaneously: the transaction is B2B, the gross total reaches PLN 15,000, and at least one line item falls within an Annex 15 category. If any single condition is not met, split payment is not required (though voluntary split payment remains an option).

Step 5: Verify the MPP annotation. Check the invoice for the phrase "mechanizm podzielonej płatności." If the annotation is missing on an invoice that meets all three conditions, notify the seller of the deficiency, but proceed with split payment regardless. The buyer's obligation to pay via split payment exists independently of whether the seller annotated the invoice correctly.

Step 6: Verify the seller's bank account on the White List. Before initiating payment, cross-reference the seller's bank account number against the official White List at podatki.gov.pl. This verification is a separate legal obligation that overlaps with split payment compliance. Paying to an unverified account exposes the buyer to joint VAT liability and loss of the right to deduct the payment as a tax-deductible cost.

Step 7: Execute the split payment. Initiate the payment using the split payment communication format in your banking system. The bank automatically splits the transfer: the net amount goes to the seller's regular operating account, and the VAT portion is directed to the seller's dedicated VAT account.

Practical Challenges at Scale

AP teams processing Polish supplier invoices in volume face several recurring friction points. Reading Polish-language line item descriptions to identify Annex 15 categories requires either Polish language proficiency or a reliable translation and classification process. Converting foreign currency totals to PLN demands referencing the correct NBP rate for each invoice date. Locating and verifying the MPP annotation text on invoices with varying formats adds another manual check. Extracting bank account details accurately for White List verification is error-prone when done by hand across hundreds of documents.

Each of these steps depends on extracting and interpreting specific data fields from the invoice itself, and errors at any point can result in penalties reaching 30% of the VAT amount shown on the invoice.

AI-powered invoice data extraction addresses these bottlenecks directly. Platforms with multi-language support and line-item extraction can analyze Polish-language descriptions to detect Annex 15 goods and services, flag invoices exceeding the PLN 15,000 threshold, verify the presence of the mandatory MPP annotation, and pull seller bank account details for White List cross-referencing. Teams that automate invoice data extraction for Polish supplier compliance can process batch volumes of up to 6,000 mixed-format documents while maintaining consistent compliance checks across every invoice.

Key Compliance Takeaways

Mandatory split payment applies only when three conditions converge: the transaction is B2B, the gross invoice value is PLN 15,000 or higher, and at least one line item matches an Annex 15 category. Both sellers who fail to annotate invoices and buyers who fail to use split payment face penalties of up to 30% of the invoice's VAT amount. White List verification is a separate but overlapping obligation that carries its own penalties for non-compliance. The upcoming KSeF mandate does not alter split payment rules or thresholds but introduces parallel e-invoicing requirements that AP teams must manage alongside their existing split payment processes.