A tax adviser's client — checked before you take the engagement.
A tax adviser's client — checked before you take the engagement.
Tax advisers, statutory auditors and providers of bookkeeping services are obliged entities. Enter a NIP: owners, sanctions, PEP, VAT status, overdue financial statements and a risk score — in one report, invoiced to the practice.
- Sanctions: MSWiA, EU, OFAC
- KNF warnings
- Beneficial owners (CRBR)
- Financials and filings
- Bankruptcy, liquidation, KRZ
- VAT status and accounts
- Press coverage
- 0–100 risk score and PDF
Money back if the report cannot be generated
For companies: the first 2 reports free (in Polish)
The tax adviser as an obliged entity
Tax advisers and statutory auditors are obliged entities (art. 2(1)(15) of the AML Act); since 2021 the Act also covers businesses whose main activity is keeping tax books, preparing returns and advising on them. Unlike attorneys and legal advisers, a tax adviser's duty is not limited to a catalogue of transactions — it applies to establishing a business relationship with a client within tax advisory.
For a tax practice this means: every new ongoing engagement is the moment to apply due diligence. Category details: obliged entities.
Four duties of an adviser towards a client.
The Act demands a risk-based approach: the higher the client's risk, the more you must establish and document.
How it looks today
Before taking an engagement the adviser checks KRS, because the contract needs the data, and the white list, because an invoice will follow. The CRBR and sanctions lists — rarely. Financial statements are opened only when the engagement concerns them. The client risk assessment is in the procedure, but for a specific client it comes down to "low" for lack of time.
The problem surfaces with corporate groups: the client asks for advice for three entities and the adviser knows only the one across the table.
What the report gives a tax adviser
- Full identification by NIP — KRS or CEIDG, REGON, VAT status from the white list and the EU VAT number from VIES, with the check date. A "removed" or "not registered" status is a signal before the first invoice; details: VAT white list.
- The financial domain — revenue, result, equity and filing dates from e-Sprawozdania; missing statements for recent years score points. MSiG and KRZ notices: bankruptcy, restructuring, liquidation — see KRZ.
- Owners and shareholders — CRBR and KRS side by side, discrepancies marked, the parent with its country up to two levels.
- Sanctions and PEP — every person from the registers against the lists (OpenSanctions with the MSWiA list, the EU list, OFAC SDN, KNF warnings); PEP and RCA status after the obliged-entity declaration.
- A 0–100 score in five domains and a proposed level of measures (SDD/CDD/EDD) with a list of actions. Deterministic rules, every finding with points and a source — methodology. The client risk pattern is on the client risk assessment page.
- A PDF with an identifier and a timestamp, VAT invoice to the practice.
An example from a tax practice
A client asks for tax optimisation across a group of three companies. The adviser checks each separately — three reports from the pack.
| Company | Findings | Score |
|---|---|---|
| Company A (operating) | Statements filed on time, no hits | 5/100 |
| Company B (real estate) | No statements for the last 2 years, negative equity | 45/100 |
| Company C (holding) | Restructuring proceedings in KRZ, foreign shareholder | 60/100 |
The report for company C proposes EDD and actions: source of funds for the advisory fees, senior management approval, agreeing the scope with the court supervisor. The adviser knows this before signing, not after the first unpaid invoice.
Documenting monitoring
Ongoing monitoring does not mean checking daily. A documented rhythm is enough: a new report when circumstances change (a new shareholder, a new kind of engagement, a KRZ entry) and at a fixed interval set by the risk level — for example every 12 months for low risk and every 6 for high. Every report has a date and an identifier, so the check history builds itself. Alerts on registry changes are planned; today the next report comes from a pack with no expiry. More: counterparty monitoring.
Legal status as of October 2026. Informational material, not legal advice.
The pack of 20 — for a tax advisory practice.
Registry data and VAT status are free. The full report with financials, owners, sanctions and the score costs PLN 39.36; the pack of 20 — PLN 298.89 (PLN 14.94 a report), no expiry, VAT invoice. Packs: /pakiety.
Questions from tax advisers.
Check a client by NIP.
VAT status, financial statements, KRZ, owners, sanctions and a risk score — one PDF before you take the engagement, in up to 3 minutes.