VIES 2026
verifying an EU counterparty — with VAT-EU and without
VIES (VAT Information Exchange System) is the official European Commission tool for verifying the activity of VAT-EU numbers. Checking a counterparty before a transaction is not only a best practice — during a tax audit, evidence of verification is the key to protecting your 0% rate on WDT and proving due diligence. We explain how to verify, what to do when a counterparty has no VAT-EU, and what to document.
Why verification of an EU counterparty is critical
Verification of an EU counterparty protects against two main risks:
1. Loss of the 0% rate on WDT. Under art. 42 sec. 1 point 3 of the Polish VAT Act, the supplier must hold an active VAT-EU number of the buyer on the transaction date. If the buyer lost their registration (e.g. their tax office deregistered them), and you applied the 0% rate — you lose the rate. Consequence: 23% VAT out of your own pocket plus possible sanctions.
2. Denial of the right to deduct VAT (due diligence). For WNT and acquisition of art. 28b services — if the EU counterparty runs a VAT carousel or is a 'missing trader,' the tax authorities may deny your right to deduct VAT. Defense: evidence that you exercised due diligence (including verification of the VAT-EU number).
State after the 2020 NSA ruling: the court confirmed that merely having an active VAT-EU in VIES does not exempt from further verification — "reasonable caution" is required. This means checking the counterparty in multiple sources.
How to use VIES — step by step
The VIES system is available at ec.europa.eu/taxation_customs/vies/. Use is free and requires no registration.
Step 1. Select the buyer's country from the dropdown (e.g. "Germany").
Step 2. Enter the VAT-EU number without the country prefix — e.g. instead of "DE123456789" enter "123456789".
Step 3. Optionally enter your own VAT-EU number with PL prefix — you will then receive a query reference number, which is proof of verification at that moment. This is critical during an audit — without a reference number, the tax office may challenge the verification date.
Step 4. Click "Verify". Result:
- "Valid" — number active, you can apply the 0% rate (for WDT) or reverse charge (for art. 28b services),
- "Invalid" — number inactive or unknown, halt the transaction or apply the Polish VAT rate,
- "Service unavailable" — temporary technical problem with the counterparty country's system, try again later.
Step 5. Print the result or save a screenshot with date and reference number. Keep in the transaction documentation for at least 5 years (until tax expiry).
VIES API — mass verification in accounting software
The European Commission provides a SOAP API for VIES (checkVatService.wsdl) — it allows accounting software (including Księgowość 365, Comarch Optima, InFakt) to automatically verify VAT-EU numbers when:
- Issuing a sales invoice to an EU buyer,
- Recording a purchase invoice from an EU counterparty,
- Conducting a periodic audit of the counterparty database (e.g. monthly).
Query limit: there is no hard one, but the Commission recommends no more than 1 query per second from one IP. For larger firms with hundreds of counterparties, implementing queuing is worthwhile.
The API response contains: status (valid/invalid), company name, address (if the country provides it), and reference number. Archive all responses — they are evidence during an audit.
What to do when a counterparty has no VAT-EU
Some EU counterparties may legitimately lack an active VAT-EU number — for example:
- Small companies using equivalents of the Polish subjective exemption,
- Companies that do not engage in intra-EU transactions,
- Freshly registered companies awaiting VAT-EU assignment.
In that case you cannot:
- Apply the 0% rate on WDT,
- Report the transaction in the VAT-EU summary.
You can however (after verification in alternative sources):
- Goods sale — apply the Polish domestic rate (23%) and treat as domestic VAT transaction,
- Art. 28b services — the service still follows the rules of the buyer's country, but requires verifying the buyer's status as a taxpayer.
Alternative verification sources
When the counterparty has no VAT-EU or you wish to perform extended verification:
- Germany — Bundeszentralamt für Steuern (BZSt): qualified confirmation of Umsatzsteuer-ID at evatr.bff-online.de,
- United Kingdom (post-Brexit) — Companies House: full company data at gov.uk,
- Czechia — ARES (Administrative Register of Economic Entities): wwwinfo.mfcr.cz/ares,
- France — INSEE Sirene: sirene.fr,
- Spain — Registro Mercantil Central: rmc.es,
- Italy — Camera di Commercio: registroimprese.it,
- Netherlands — KvK Handelsregister: kvk.nl.
Other sources: Polish trade consulates abroad, foreign chambers of commerce (AHK Polen, CCIFP, etc.), paid due-diligence databases (Bureau van Dijk, Dun & Bradstreet).
Polish MF methodology — 12 due-diligence criteria
The Polish Ministry of Finance published on 25 April 2018 the "Methodology for assessing due diligence by buyers of goods". Although it concerns mainly domestic transactions, tax authorities apply similar criteria to EU transactions. 12 key questions:
- Does the counterparty hold the required licenses or permits for their industry?
- Do the persons signing the contract have authorization to act on behalf of the counterparty?
- Does the goods price significantly deviate from market price without economic justification?
- Do the offered goods belong to the counterparty's industry or are atypical for their profile?
- Does the counterparty have a physical office, branch, representative?
- Does the registered address show signs of actual business operation?
- Do the transaction terms not deviate from industry standards?
- Does the counterparty limit the possibility of returns?
- Are there free arrangements on transport, storage, place of receipt?
- Is the planned transaction documented by contract, order?
- Does the counterparty have organizational-technical infrastructure appropriate to their scale?
- Does the counterparty have a website with information matching their scale?
The more "yes" answers — the greater the due diligence. Keep screenshots, correspondence, contracts in documentation.
What to archive — checklist for every transaction
For every transaction with an EU counterparty, archive:
- ✅ VIES screenshot with date and reference number (before transaction),
- ✅ Printout from local register of the counterparty (e.g. Handelsregister DE, ARES CZ),
- ✅ Order / contract with defined terms,
- ✅ Sales or purchase invoice with VAT-EU prefix of both parties,
- ✅ Delivery confirmation (CMR, transport document, receipt email),
- ✅ Payment confirmation (bank transfer with description),
- ✅ Correspondence with the counterparty (email, chat, telephony — optional).
Storage period: 5 years from the end of the year in which the tax-payment deadline expired (under art. 86 §1 of the Polish Tax Ordinance).
Frequently asked questions
What to do if VIES returns 'Service unavailable' on the very day of my delivery?
Try again in 15-30 minutes — a common technical problem with country systems. If the issue persists for several hours, archive the screenshot with the error message (as evidence of attempted verification), verify the counterparty in their country's local register, and complete the VIES verification at the first available moment, attaching it to the documentation.
Do I have to verify the counterparty before every transaction, or is once enough?
Best practice: verification before every transaction, or at least monthly for regular counterparties. A VAT-EU number can be invalidated at any time (the counterparty's tax office can deregister them). A one-time verification from 2024 does not protect you for a 2026 transaction.
Can I rely on data from the counterparty's invoice?
No. The mere fact that the counterparty wrote a VAT-EU number on the invoice is not proof of activity. The number must be verified in VIES — this is the supplier's responsibility. Tax authorities regularly deny the 0% rate on WDT to firms that 'trusted the counterparty's word'.
What if a German counterparty gives me 'Umsatzsteuer-ID' and 'Steuernummer' — which to use for verification?
Enter the **Umsatzsteuer-ID** (USt-IdNr) into VIES — that is the VAT-EU number with DE prefix. **Steuernummer** is the local German tax number not used in EU transactions. Format: DE + 9 digits (e.g. DE123456789).
Is VIES verification enough to prove due diligence?
Insufficient but necessary. VIES confirms only the activity of the VAT-EU number — it does not verify whether the counterparty actually conducts business or is not a 'missing trader'. For full due diligence, add verification in the local register, check the website, business correspondence and documents (see MF methodology of 25.04.2018).
Need help with verifying EU counterparties?
We help Księgowość 365 clients organize the verification process: built-in VIES checks for every invoice, archiving of screenshots with date, integration with the Polish White List, regular audits of the counterparty database. This is the foundation of protection against sanctions and 0% rate denial.
For sales teams we also provide a quick-check protocol — a step-by-step verification of new buyers before signing a contract.
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Marek specializes in corporate finance, international transactions, due diligence and verification of foreign contractors.