Since 2013, the Czech Financial Administration has publicly marked VAT payers that seriously breached their obligations as "nespolehlivý plátce DPH" (unreliable VAT payer). On 11 October 2026 the register's web service returned a list of 4,365 unreliable payers (description of the register and service, in Czech); the number changes continuously. The consequences for their trading partners can be severe. If you source goods or services from Czech businesses, understanding this mechanism is not optional — it is a basic financial safeguard.

The Legal Background

The concept is anchored in the Czech VAT Act (Act No. 235/2004 Coll.), specifically:

  • § 106a — defines when the Tax Administration assigns the "unreliable payer" status to a VAT-registered entity that has seriously violated its obligations relating to tax administration. The Act does not list the individual grounds; they are assessed by the tax administrator.
  • § 106aa — extends the concept to an "unreliable person", i.e. a person who is not a VAT payer and seriously breached those obligations.
  • § 109 — the critical liability clause: a VAT payer who receives a taxable supply is liable for the unpaid VAT on that supply if they knew, or should and could have known, that the tax would deliberately not be paid. The Act lists situations in which that knowledge is presumed.

The status is published in the VAT payer register of the Czech Financial Administration. A payer may apply for a decision that it is no longer unreliable no earlier than one year after the decision became final (§ 106ac).

When Does Liability Attach to You?

Under Section 109(2), the buyer is presumed to have known that the tax would not be paid in several situations. For ordinary purchases the main ones are these — each is sufficient on its own:

  • It is published that the supplier is an unreliable payer.
  • You pay by bank transfer to an account other than the supplier's account published by the tax administrator.
  • The price deviates obviously from the usual price without economic justification, or the payment is made in cash above the statutory limit or in a virtual asset.

In practice, this means paying a correct invoice in full is not enough. Liability is therefore not limited to unreliable payers: paying an otherwise unproblematic supplier to an unpublished account is a separate ground.

How to Check a Supplier

The official tool is the VAT payer register on the Financial Administration portal. You search by VAT number (DIČ) and see whether the entity is a registered payer, whether it is marked as unreliable and which bank accounts it has published.

For a single supplier, this is straightforward. However, for procurement or accounting teams managing dozens or hundreds of vendors, manual portal checks quickly become impractical — and gaps in coverage create legal exposure.

Scaling Checks Across Your Supplier Base

For organisations that work with many Czech counterparties, the Financial Administration operates a web service intended for accounting and other third-party software. It returns the reliability status, published bank accounts and tax office number for the VAT numbers submitted, and can return the full list of unreliable payers.

Databázekontaktu.cz supplies one-off industry exports with available VAT-registration and insolvency data. We confirm coverage and the data date when you order. The file does not update automatically; check the relevant public register for current status before an important decision. See our data methodology (Czech) and industry export prices (Czech).

A Practical Protection Checklist

  1. Before the first order: verify the supplier's DIČ/IČO against the unreliable payer register.
  2. Before every payment: confirm the invoice bank account matches an account declared by the supplier in the official register.
  3. Monthly sweep: re-verify your entire active supplier list — status can change at any time.
  4. Uncertain cases: consult a tax adviser. For these cases the Act provides a "special method of securing tax" (§ 109a), under which the buyer pays the VAT for the supplier directly to the supplier's tax administrator.

Conclusion

The Czech unreliable VAT payer regime places a real due-diligence burden on buyers, not just suppliers. For companies procuring in Czechia, checking the supplier and the bank account before payment is the practical safeguard. This article is informational and not tax or legal advice. Other public sources for partner screening are covered in ARES, Insolvency & Contract Register: Czech Public Data Explained.