# 🇨🇿 Czech Republic — the Unreliable VAT Payer Register and How Podnikio Checks It
2026-09-14 — Podnikio Team
Paying a Czech 'nespolehlivý plátce', or paying any VAT payer into an unpublished bank account, can make you liable for their unpaid VAT. Here's how the register works, when it matters, and how Podnikio checks it automatically for you.
A domestic Czech invoice between two DIČ-registered businesses looks like the simple case — no reverse charge, no VIES, just VAT at the usual rate. It is, except for one thing worth checking before either side gets paid: whether the supplier is an **unreliable VAT payer** (*nespolehlivý plátce*), and whether the account being paid is one they have actually **published**.
## Quick answer
The Czech tax administration (ADIS) publishes, for every DIČ, whether the holder is currently registered, whether they are flagged as an **unreliable VAT payer**, and which bank accounts they have **published** for receiving payment. Paying an unreliable payer — or paying *any* VAT payer into an account they have not published — makes the **payer** jointly liable (*ručení za daň*, § 109 of the VAT Act) for the VAT that supplier fails to remit on that transaction. There is no minimum invoice amount; it applies from the very first crown. Podnikio checks both conditions automatically for you.
## Main takeaways
Two independent triggers create joint liability: the supplier being an unreliable payer, or the payment going to an unpublished account.
There is no minimum invoice value — the rule applies to any domestic B2B payment.
"Unreliable VAT payer" (nespolehlivý plátce) is a different category from "unreliable person" (nespolehlivá osoba) — the latter applies to someone not currently a VAT payer at all.
Podnikio checks your supplier's, client's as well as your own reliability status, and your own bank account, against ADIS automatically.
## Why it matters
§ 109 of the Czech VAT Act makes the **recipient of a taxable supply** liable for VAT the supplier does not pay, if the recipient knew or should have known, at the time of payment, that:
- the supplier had been published as an **unreliable VAT payer**, or
- the payment was made to a bank account that is **not published** for that supplier in the VAT payer register.
Either is enough on its own — reliability and account publication are two separate checks, not one. Because the register is public and the tax office treats it as something any reasonable business would have consulted, "I did not check" is not a defence. Checking it, and being able to show when you checked, is what establishes that you acted with reasonable care.
This liability attaches to the **payer**. As the party issuing the invoice, it is *your* status and *your* account being scrutinised by whoever is about to pay you — which is exactly why it is worth confirming before you send the invoice, not after a client's accountant flags it and delays the payment.
## What counts as "unreliable"
ADIS distinguishes a few statuses that are easy to conflate:
- **A reliable VAT payer** — the ordinary case.
- **An unreliable VAT payer** (*nespolehlivý plátce*) — flagged after a serious breach of their VAT obligations. Some grounds require a repeated pattern (for example, missing filings twice within a year); others, like a single unpaid VAT assessment over CZK 500,000, are enough on their own. This is the status that triggers § 109 liability.
- **An unreliable person** (*nespolehlivá osoba*, § 106aa) — someone who **is not currently a VAT payer at all**, flagged for the same kind of serious breaches, and often carried over from before their VAT registration lapsed — the category exists specifically so deregistering doesn't wash the flag away, and re-registering brings it straight back as an unreliable *payer*. It does **not** carry the same § 109 joint-liability consequence, since a non-payer isn't charging you VAT in the first place; it is still a real red flag about who you're dealing with, and Podnikio surfaces it with its own wording.
- **An identified person** (*identifikovaná osoba*) — registered only for cross-border reverse charge, never a full domestic VAT payer. Not the same risk profile as either of the above.
- **Not found** — no DIČ registration exists at all.
## How Podnikio checks it for you
Podnikio queries ADIS's own web service directly, in real time:
- **Your reliability status is checked** automatically, using the VAT number on your company profile — active and reliable, or flagged, shown plainly.
- **Your invoice's bank account is checked** against your own published accounts, as soon as you set a bank-transfer payment method with an IBAN — matched against both the standard Czech account format and the alternative "non-standard" format ADIS also publishes.
- **You get a warning immediately** if either check comes back unfavourable.
- **Your supplier's and client's own status is checked too**.
No manual visits to the tax portal, no remembering to re-check before a big invoice — Podnikio runs the same lookup ADIS itself would answer, automatically.
## Frequently asked questions
### Is there a grace period, like Poland's ZAW-NR?
Not the same mechanism. Czech law does not offer an equivalent "notify within a deadline and you are off the hook" filing. It does offer a different opt-out: under § 109a, you can pay the VAT portion of the invoice directly to the supplier's tax administrator (and only the net amount to the supplier), which takes that payment out of § 109 liability entirely — but that has to be arranged with the supplier per payment, not filed after the fact. The practical protection for everything else is checking **before** you pay — the point of § 109 is that the payer had the means to know and acted anyway (or without checking).
### Does this apply to invoices to consumers?
No — it is a B2B rule between VAT payers. A private individual paying an invoice is not exposed to joint liability for the supplier's VAT.
### My client is an identified person, not a full VAT payer. Does the unreliable-payer check still matter?
An identified person cannot be flagged as an unreliable VAT payer in the first place — that status only applies to full VAT payers. Podnikio's check recognizes an identified person as exactly that internally, rather than lumping them in with "not registered" — so you won't get a false inactive-VAT-number warning about a client who is legitimately registered, just in a limited capacity.
### Does this replace VIES?
No. This is Czechia's **domestic** register; [VIES](/en/blog/overview/vies-vat-number-validation-2026) is the EU's cross-border one, and it does not know about domestic reliability status or published Czech bank accounts at all. Podnikio runs whichever check actually applies — domestic reliability and account publication for a Czech client, VIES for a cross-border one.
## Contact us
If you are unsure how the unreliable-payer register or the joint-liability rule applies to a specific payment, feel free to reach out. We offer a free initial consultation.
## Related posts
- [What Is VIES, and How Podnikio Checks EU VAT Numbers for You](https://www.podnik.io/en/blog/overview/vies-vat-number-validation-2026)
- [🇵🇱 Poland — the VAT Whitelist (biała lista) and How Podnikio Checks It for You](https://www.podnik.io/en/blog/poland/vat-whitelist-biala-lista-2026)
- [🇸🇰 Slovak Republic — the VAT Payer Register and How Podnikio Checks It](https://www.podnik.io/en/blog/slovak-republic/vat-payer-register-2026)