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CZ/SK Supplier Reliability Check

Before you pay a supplier, checks the tax authority's registers for the supplier's reliability and for the bank account you are paying, and keeps the answer on the bill and the payment as evidence.

What it is for

In both countries a VAT payer who buys from a supplier can be made to pay the supplier's unpaid VAT — ručenie za daň in Slovakia, ručení za nezaplacenou daň in the Czech Republic. Two of the circumstances that trigger it can be checked in public registers before you pay:

• whether the supplier is flagged by the tax authority (CZ: nespolehlivý plátce; SK: on the list of payers with grounds for cancelling the registration);
• whether the bank account you are paying is one the supplier has published with the tax authority.

This module asks those registers when a vendor bill or a supplier payment is posted, writes the answer onto the document with a timestamp, and shows a warning when there is a risk. It never blocks posting or paying: the decision stays with you, and the record shows what the register said at the time.

The module itself holds no register connection. The lookups come from a country provider:

Without a provider for the supplier's country every check comes back Not checked / unavailable, without a warning.

Legal background

Slovakia — zákon o DPH:

• Under § 69 ods. 13 the platiteľ who receives a supply is liable (ručí) for the VAT on the supplier's invoice that the supplier did not pay, if it knew or should have known that the tax would not be paid. Písm. c) names, as a sufficient reason, paying to an account other than the supplier's account that was published on the day of payment in the list of bank accounts; the day of payment is the day you gave your bank the payment order.
• The list itself is published under § 6 ods. 6.
• § 69 ods. 14 has the Financial Directorate publish the payers for whom grounds for cancelling the registration under § 81 ods. 3 písm. b) second point arose (repeated failure to file or pay, not reachable at the registered address, and similar).
• The liability itself is enforced under § 69b; § 69c lets the customer pay the VAT from the invoice directly to the tax administrator's account kept for the supplier (osobitný spôsob úhrady dane).
• The index daňovej spoľahlivosti (highly reliable / reliable / less reliable) is set under § 53d of the daňový poriadok and published under § 52 ods. 17. It is not one of the § 69 ods. 13 reasons; the module shows it as additional information.

Czech Republic — zákon o DPH, § 106a, § 109, § 109a:

• § 106a: the tax administrator decides that a payer who seriously breaches its obligations is a nespolehlivý plátce.
• § 109 odst. 2: the recipient is presumed to have known that the tax would not be paid — and is liable for it — among other cases when the supplier is published as a nespolehlivý plátce (písm. a)), or when the payment goes by bank transfer to an account other than the supplier's account published by the tax administrator (písm. c) bod 2).
• § 98 písm. d): the published accounts are those the payer named for publication in its registration.
• § 109a: the recipient can pay the supplier's VAT directly to the supplier's tax administrator (zvláštní způsob zajištění daně).

Setting it up

Accounting → Configuration → Settings, block Vendor Bills, setting Supplier reliability check (CZ/SK). It is on by default for every company; switch it off per company if you only want to check by hand.

The check runs only for companies whose fiscal country is Slovakia or the Czech Republic. Install the provider for each country your suppliers come from; the Slovak one also needs an API key (see below).

The supplier needs the identifier the register searches by:

The bank account you pay is compared with the register's list as an IBAN. A Czech supplier's account may also be entered in the domestic form (19-2000145399/0800); the Czech provider converts it to IBAN first.

When the check runs

• Posting a vendor bill or a vendor credit note — automatically, if the setting is on.
• Posting an outbound supplier payment — automatically, against the account the payment actually goes to. This is the moment the liability depends on, and weeks can pass between the bill and the payment.
• Every day — the scheduled action Supplier reliability: re-check unpaid bills (CZ/SK) re-checks posted bills that are not yet paid (or only partly paid) and were last checked more than 7 days ago, at most 200 per run, the oldest checks first.
• By hand — Check supplier reliability, under the recipient bank account on a vendor bill and under the vendor bank account on a supplier payment. It works in any state, including draft, and whether or not the setting is on.
• On the contact — Actions → Check tax reliability in the contact list or form asks for the rating only, for every selected contact's company.

Every check that gets a rating also writes it to the supplier's contact, as Tax Reliability with the time of the check, next to its Tax ID.

A register that does not answer never stops a posting; the document then shows Not checked / unavailable.

What you see

On the vendor bill (and the payment), next to the bank account:

A warning banner appears at the top of the document, and the same text is posted in the chatter, when:

• the account being paid is not among the registered accounts — with its own wording when the supplier has published no account at all;
• the rating is Less reliable or Unreliable;
• the supplier is on the deregistration list.

Each new check replaces the snapshot on the document; the chatter keeps the earlier warnings. The snapshot fields are read-only and are not copied when a bill is duplicated.

What to do about a warning is your decision: pay a published account instead, or pay the VAT directly to the supplier's tax administrator (§ 69c SK / § 109a CZ) and the rest to the supplier.

Czech provider (ADIS)

l10n_cz_payment_reliability asks the Ministry of Finance web service rozhraní CRP DPH (the public part of the VAT payer register) about suppliers whose country is the Czech Republic. It needs no account or key. One request answers both questions:

The published accounts come back in the domestic form (předčíslí–číslo/kód banky); the module converts them, and an account typed on the bill in that form, to IBAN before comparing. Accounts the register publishes in another form (foreign IBANs) are compared as published. The Czech register has no deregistration list, so that field stays empty for Czech suppliers.

Slovak provider (Financial Administration open data)

l10n_sk_payment_reliability uses the open-data service of the Finančná správa (opendata.financnasprava.sk), which requires a free API key. Request a key there and enter it under Accounting → Configuration → Settings, in the Supplier reliability check (CZ/SK) setting, field FS open-data API key. The key is shared by all companies of the database. Without it every Slovak lookup is Not checked / unavailable.

Before searching the deregistration list the module asks the service whether that data set can be searched by IČ DPH. If it cannot, the field stays empty and the check counts as unavailable rather than as a clean record.

Limitations

• Warns, never blocks. Nothing stops you posting or paying an unregistered account.
• A Slovak empty list warns. When the Slovak list holds no account for the IČ DPH on the contact, the warning says the supplier has published none. For a platiteľ that is the liability case itself; but the Slovak data set cannot tell a platiteľ with no account from a subject that is not a platiteľ (for example a § 7 or § 7a registrant, whose IČ DPH is on no list of accounts). Check the supplier's registration before relying on it. A Czech supplier that ADIS does not hold as a plátce is reported as Not checked / unavailable instead.
• Domestic account forms are understood for Czech suppliers only. A Slovak account must be entered as IBAN.
• Day of payment. The law looks at the list on the day you give the payment order. The module checks when the payment is posted in Odoo; if you send the order to the bank later, check again.
• Suppliers from other countries are not checked. A supplier without a country (Czech provider) or without the identifier the register needs comes back Not checked / unavailable, without a warning.
• The Tax Reliability on the contact is the latest rating any check obtained; the bill and payment snapshots remain the record of what the register said at each moment.
• The Slovak deregistration data set name (ds_dphz) has not been confirmed against the live service; if it is wrong the field simply stays empty.
• A check records what the register said; it does not prove that the supplier will pay its VAT, nor that you could not have known otherwise.