Split payment in a sole proprietorship (JDG) in Poland in 2026 — when the MPP is mandatory

The three conditions for mandatory MPP

The split payment mechanism is applied on a mandatory basis when, together:

1. the payment relates to an invoice between taxpayers,
2. the total amount due on the invoice exceeds 15,000 zł gross,
3. the invoice includes at least one item from Annex 15 to the VAT Act.

The annex covers, among other things, selected sensitive goods, electronics, fuels, steel, waste and certain construction services. The scope must be checked against the specific item, not the seller's industry.

Exactly 15,000 zł

An invoice equal to 15,000 zł does not exceed the threshold. For example, 12,195 zł net + 2,805 zł VAT = 15,000 zł gross is not covered by mandatory MPP on account of the amount alone.

Voluntary split payment may still be used if the document and the accounts allow such a transfer.

A mixed invoice

If an invoice exceeds the threshold and includes both items from Annex 15 and other items, the obligation covers at least the amount attributable to the items covered by the annex.

In practice you can pay the entire invoice by MPP to simplify the process. The document should carry the marking "mechanizm podzielonej płatności" (split payment mechanism).

How to make the transfer

In their banking, the buyer selects the MPP transfer message and enters:

• the gross amount,
• the VAT amount,
• the invoice number,
• the seller's NIP.

The bank debits the buyer's account and splits the funds:

• the net amount to the seller's current account,
• the VAT to the linked VAT account.

The buyer does not make two ordinary transfers.

The seller's account

MPP works on a current account for which the bank maintains a VAT account. A private personal account (ROR) is not a suitable account for receiving an MPP message.

A seller covered by the obligation should provide an account that allows split payment and mark the invoice correctly.

The whitelist

A payment under mandatory MPP may limit certain risks tied to an account outside the whitelist. It does not, however, release you from checking the counterparty's data and the correct account number.

The whitelist and MPP are related but are not the same obligation:

• the register concerns the account and the taxpayer's status,
• MPP concerns the method of paying a specific invoice.

Voluntary MPP

The buyer may apply split payment voluntarily, including for a lower amount or an item outside Annex 15, provided they pay an invoice showing VAT to the correct account.

The seller should not describe a voluntary payment as one that is statutorily mandatory.

How funds in the VAT account can be used

The funds are not "frozen solely for paying the VAT shown on invoices." The Act allows them to be used for certain public-law liabilities and for MPP payments, including VAT, part of other taxes, customs duty and ZUS contributions, in line with the current catalogue.

You can also apply for the funds to be transferred to your current account. The head of the tax office issues a decision within the statutory deadline and may refuse in certain situations.

No marking on the invoice

If the transaction meets the conditions, the seller should add the words "mechanizm podzielonej płatności." A missing marking may lead to sanctions, but it does not release the buyer from applying MPP if they are aware of the nature of the transaction.

The error should be corrected and documented. The sanction consequence depends on the circumstances and the parties' actions — you should not assume a single automatic penalty in every case.

No MPP on the buyer's side

Paying by an ordinary transfer despite the obligation may lead to:

• an additional VAT liability,
• fiscal-penal liability,
• exclusion of the expense from PIT/CIT costs to the appropriate extent.

It does not automatically mean that every part of the input VAT from the invoice becomes non-deductible. You have to separate the right to deduct from the sanction for the method of payment.

Set-off and other forms of settlement

For set-off, netting, factoring or payment by a third party, the rules require a separate analysis. Not every amount settled without a transfer is subject to identical MPP consequences.

You should not get around the obligation by artificially splitting a payment.

KSeF

KSeF does not perform split payment. It can convey the invoice marking and payment data, but the bank's MPP message is still submitted by the buyer or their payment system.

Not every invoice in KSeF is covered by MPP.

The most common mistakes

1. Using MPP for every invoice above 15,000 zł without checking Annex 15.
2. Treating an invoice of exactly 15,000 zł as exceeding the threshold.
3. Two ordinary transfers instead of an MPP message.
4. Paying to a private personal account (ROR).
5. The seller failing to mark the invoice.
6. Assuming that a missing note releases the buyer.
7. Confusing the MPP consequences with the right to deduct VAT.
8. Assuming that funds in the VAT account cannot be used for ZUS or other permitted liabilities.
9. Confusing KSeF with a bank payment order.

Sources

• Podatki.gov.pl — the split payment mechanism
• The VAT Act — ISAP

Want to check an invoice before the transfer?

Oxyok monitors MPP, the whitelist and the booking of payments. Accounting costs from 49 zł + VAT per month.

Write to Paweł or see Oxyok accounting.

This material is general in nature. The obligation depends on the value of the entire invoice, its items, the status of the parties and the method of payment.