An "unreliable VAT payer" (nespolehlivý plátce DPH) is a designation assigned by the Czech Financial Administration to companies and individuals who repeatedly or seriously violate their VAT obligations. The published list is freely available online. If your supplier issues invoices with VAT, you should check this list before the first payment — you could face direct financial liability.

Who ends up on the list

The Financial Administration adds a VAT payer to the list when they seriously or repeatedly breach tax obligations, including:

  • Failing to remit VAT despite demands from the tax authority
  • Repeatedly failing to file VAT returns or recapitulative statements
  • Participating in fraudulent transactions (carousel fraud, artificial supply chains)

The designation is not permanent — a company can leave the list by demonstrating proper compliance. In practice, companies tend to remain on the list for months or years.

Joint liability — the biggest risk

This is the most practically important reason to monitor the register. The VAT Act (§ 109) establishes the principle of joint liability: if you accept an invoice from an unreliable VAT payer and the supplier fails to remit the VAT, the tax authority can pursue the unpaid tax directly from you.

In other words: you pay VAT twice. Once to the supplier as part of the price, and once to the tax authority as the guarantor. There is no statutory cap on liability — it covers the full VAT amount on the invoice.

Joint liability also applies to payments made to a bank account not published in the register. If you pay to a different account than the one listed, you are automatically liable — regardless of whether the supplier is on the blacklist or not.

How to verify a supplier's VAT status

  1. Firmometr — enter the company ID (IČO); VAT status including published bank accounts appears immediately in the company profile
  2. Czech Financial Administration VAT register — application on mfcr.cz, searchable by IČO or VAT number (DIČ)

Check every time you start working with a new supplier. Monitor key partners on an ongoing basis.

Verifying the bank account on the invoice

VAT payers are legally required to publish the bank accounts they use for business in the Financial Administration register. Before every payment of a VAT invoice, verify:

  • The account number on the invoice matches the published account in the register
  • You are paying to the correct account — not some other "operational" or "technical" account the supplier has not published

Firmometr displays the supplier's published bank accounts directly in the VAT section of the company profile.

What to do if your supplier is on the blacklist

  • Use the special tax security mechanism — send the portion of the payment corresponding to VAT directly to the deposit account of the tax office responsible for the supplier. This removes your liability.
  • Arrange reverse charge — if the transaction type permits it.
  • Consider switching suppliers — an unreliable VAT payer is typically a company in financial distress.

Ongoing monitoring

A company can be added to the list at any time — a reliable supplier today can be on the blacklist in 3 months. Firmometr will notify you by email of any change in VAT status if you add the company to your watchlist.

Summary

Joint liability for an unreliable VAT payer's unpaid tax is a real financial risk that can be easily eliminated by a simple check. Verifying VAT status before accepting the first invoice from a new supplier is a basic duty for every accountant and procurement manager. It takes 10 seconds and can save hundreds of thousands of crowns.