Since November 2019, Poland has had a mandatory split payment mechanism (mechanizm podzielonej płatności, MPP) for a defined category of B2B, VAT-taxable transactions. Here’s exactly how it works technically, who it applies to in 2026, and what happens if you get it wrong.

How split payment works

Mechanizm podzielonej płatności (MPP) means the gross amount a buyer transfers for goods or services is automatically split by the bank into two separate bank accounts belonging to the seller:

  • the net amount (the price of the goods/services excluding tax) goes to the seller’s regular business account;
  • the VAT amount goes to a dedicated VAT account (Rachunek VAT).

To pay an invoice this way through online banking, instead of a regular transfer you use a special MPP payment message, filling in 4 mandatory fields:

  • the net amount;
  • the VAT amount;
  • the seller’s NIP number;
  • the invoice number.

These 4 fields signal to the bank that it needs to split the payment automatically between the recipient’s two accounts.

Split payment has existed as a voluntary payment option since 2018, but for a defined category of transactions it became mandatory from November 2019.

The core rules on split payment sit in the VAT Act*, in a dedicated section on the “Mechanizm podzielonej płatności” (Art. 108a-108d).

*Act of 11 March 2004 on Tax on Goods and Services (Journal of Laws 2004, No. 54, item 535, as amended), original text on the Sejm’s website.

Who is subject to mandatory split payment

As of 2026, mandatory split payment applies when all three of the following conditions are met at once:

1. Invoice amount: the invoice’s gross value exceeds PLN 15,000; 2. Type of goods or services: the invoice includes at least one item listed in Annex 15 to the VAT Act: construction work, electronics (including phones and processors), fuel, coal, steel and other metals, car parts, and waste/scrap; 3. Both parties to the transaction are VAT payers (Płatnik VAT), meaning the mechanism applies exclusively to transfers between two businesses (B2B).

The mechanism does not apply to transactions with ordinary consumers (B2C) and has no relevance to anyone who doesn’t run a business in Poland at all.

If all three conditions are met, the seller must add the note “mechanizm podzielonej płatności” to the invoice. There’s no need to notify the tax office (US) in advance: the obligation arises automatically once the conditions are met.

Most IT services (as long as you’re not also selling electronics as goods) generally aren’t covered by mandatory split payment: they don’t fall under Annex 15. You can still use the mechanism voluntarily, and it can speed up VAT refunds.

The mechanism operates in Poland under a special EU derogation, currently extended at least until 29 February 2028.

What is the VAT account

Alongside a business’s regular account, the bank automatically opens a dedicated VAT account (Rachunek VAT), an additional account used specifically to settle VAT liabilities. It cannot be opened in a foreign currency, only in Polish złoty, and opening and maintaining it is free of charge for the customer.

Funds in the VAT account belong to the taxpayer, but their use is legally restricted. You can pay from this account:

  • VAT itself (including VAT on imported goods);
  • PIT and CIT, including advance payments and late-payment interest;
  • ZUS contributions;
  • excise duty and customs duties;
  • transfers to another VAT account (at the same bank).
An important update to outdated information: originally (in 2019), the VAT account could only be used to pay VAT itself. Following the SLIM VAT amendments, the list was expanded: you can now also pay PIT, CIT, ZUS, excise duty, and customs duties from it (Art. 108b of the VAT Act, Art. 62b of the Banking Law).

You still cannot use this account to pay employee salaries, office rent, or a car lease: those expense categories remain outside the statutory list. If you need to move funds from your VAT account for a purpose not on that list, you have to apply to the head of the tax office to have those funds “released.”

Consequences of not applying mandatory split payment

There are two separate scenarios to keep in mind:

1. The seller fails to add the mandatory note “mechanizm podzielonej płatności” to the invoice. This triggers an additional tax liability of 30% of the VAT amount on the Annex 15 items (Art. 106e(12) of the VAT Act). In practice, this penalty isn’t applied if the buyer still paid through split payment despite the missing note, since the purpose of the rule has already been achieved.

2. The buyer doesn’t pay through MPP when they were required to. This triggers an additional tax liability of 30% of the VAT amount on the Annex 15 items (Art. 108a(7) of the VAT Act).

Important exception (Art. 108a(8)): the 30% penalty for the buyer does not apply if the seller has fully settled the VAT from that invoice with the tax office, even if the payment itself was made outside the MPP mechanism.

On top of the 30% penalty, an expense paid in breach of mandatory split payment can also be excluded from tax-deductible costs (KUP).

FAQ

Does split payment apply to transactions with private individuals? No, the mechanism only applies to transactions between two VAT payers (B2B). Sales to ordinary consumers (B2C) are outside the scope of mandatory split payment.

Can I use split payment voluntarily, even if a transaction doesn’t meet the mandatory conditions? Yes, split payment can be applied voluntarily to any transaction, and among other things, it can speed up the VAT refund process from the tax office.

What happens if, as a buyer, I mistakenly didn’t use MPP on a mandatory transaction, but the seller fully settled the VAT? In that case, the 30% VAT penalty won’t apply to you: the law explicitly provides for this exception (Art. 108a(8) of the VAT Act).

Bibliography and legal basis

  • Art. 108a-108d, 106e(12) of the Act of 11 March 2004 on Tax on Goods and Services (Journal of Laws 2004, No. 54, item 535, as amended): the split payment mechanism, penalties, Annex 15.
  • Art. 108b of the VAT Act and Art. 62b of the Banking Law: the expanded list of payments allowed from a VAT account (PIT, CIT, ZUS, excise duty, customs duties).
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Author: MojaFirma team.

This article is for informational purposes only and does not constitute legal advice. Every situation depends on the specific contract and individual circumstances. If something about your own situation isn’t quite clear, feel free to book a free consultation with our team.