From 7 January 2020, we will offer the possibility of verifying account numbers of recipients against the whitelist in mBank CompanyNet.

When ordering a domestic transfer in mBank CompanyNet, you will decide whether you want the bank to verify if the counterparty’s account number is on the whitelist. The service will be offered free of charge regardless of the transfer amount. All you need to do is enter the recipient’s tax identification number (NIP) and select the account verification option. If the account is not on the whitelist, we will reject the transfer at the posting stage. You will decide what to do next.

The following functionalities will also be available from January 2020:
1. When importing split payment transfers, you will be able to select the option of verifying all imported transfers against the whitelist;
2. In mBank CompanyNet system settings, you will be able to select the option of verifying counterparty account numbers against the whitelist by default:
a. in the new domestic order form,
b. in all split payment transfers ordered using the Connect systems.

We hope that the new features will make your work faster and easier. We plan to further develop the solution in the future.


What is the whitelist?

The whitelist was introduced on 1 September 2019 by the Act of 12 April 2019 on Amendments to the Goods and Services Tax Act and Certain Other Acts.

The whitelist is an electronic register of VAT payers maintained by the Head of the National Revenue Administration comprising entities:

• registered as VAT payers, including those which have been re-registered as VAT payers, along with their statuses, tax identification numbers (NIP), statistical numbers (REGON) and bank account numbers;
• which have not been registered as VAT payers or have been removed from the register of VAT payers by the head of the tax office.

The register includes:

• bank account numbers of entrepreneurs within the meaning of the Banking Law Act, to which counterparties are to make payments, or
• personal accounts kept with cooperative savings and credit unions of which given entities are members, opened in connection with the pursued business activity,
  as indicated in an identification notification or in an update notification.

In accordance with the Act, the whitelist includes settlement accounts of taxpayers reported to the tax office and confirmed by the bank with the use of IT System of the National Clearing House (STIR) (Article 96b (3) (13) of the Goods and Services Tax Act).
Savings and checking accounts (ROR), custody accounts, and banks’ own accounts (assignment accounts, factoring settlement accounts) will not be included on the whitelist, even if you reported them to the tax office.

From 1 January 2020, payments to accounts from outside the whitelist will result in sanctions:

• with regard to PIT/CIT – non-tax-deductibility of such payments;
• joint and several liability for the VAT arrears arising from the settled invoice.

Note: Payments to assignment accounts and factoring settlement accounts
We will make payments to accounts under agreements based on receivables purchase and subrogation in accordance with the requirements of the abovementioned Act. As regards payments to assignment accounts or factoring settlement accounts, we are working on an alternative solution based on the decisions of the Ministry of Finance.

Should you have any questions, please do not hesitate to contact your account manager.