Company bank account blocked by the tax authority in Poland (STIR): 72 hours, extension to 3 months and what can still be paid

A STIR block is not the same as a seizure for tax arrears, and not the same as a block imposed by the bank itself. It has its own authority, its own deadlines, its own list of accounts and its own remedies. Almost everything you can do depends on recognising it in the first hours: the first 72 hours are the window in which it is decided whether the block lapses or is extended.

In Polish it is blokada rachunku podmiotu kwalifikowanego; colloquially, "blokada STIR" or "skarbówka zablokowała konto". STIR is the name of the system through which banks send the tax administration daily data on movements in business accounts. The authority is the Szef Krajowej Administracji Skarbowej — the Head of the National Revenue Administration, written below as the Head of KAS.

Tax authority blocked the account or seized it: which case is yours

The key difference: a seizure takes the money, a STIR block holds it. In a seizure the funds go towards the arrears; in a block they stay on the account but you cannot use them. The two can meet — see the section on when the block lapses.

Who imposes a STIR account block and on what grounds

The basis is art. 119zv § 1 of the Ordynacja podatkowa, the Polish Tax Ordinance. The block is requested by the Head of KAS, not by the head of the tax office, and may be requested where available information, in particular the results of risk analysis, indicates that the entity may use banks or credit unions (SKOK) for purposes connected with tax fraud, and the block is necessary to counter this. The head of the tax office, the head of the customs and tax office and the prosecutor receive a notice of the block from the Head of KAS (§ 3 pt 2).

"Tax fraud" (wyłudzenia skarbowe) is a closed list of offences, not any tax problem (art. 119zg pt 9). It covers tax evasion and several other offences under the Fiscal Penal Code (arts 54, 55, 56, 62 and 76), invoice offences under the Criminal Code (arts 270a, 271a, 277a) and an organised group aiming at them (art. 258). Tax arrears on their own are not grounds for a STIR block — for arrears the tax office enforces, and that is a seizure.

The risk analysis is carried out by the Head of KAS (art. 119zn § 1), and the STIR system calculates a risk indicator for each entity at least once a day (§ 2). The statute lists five groups of criteria (§ 3): economic — transactions not justified by the nature of the business; geographic — transactions with parties from countries at high risk of tax fraud; subject-matter — high-risk lines of business; behavioural — conduct unusual in the given situation; and links with entities that carry such a risk.

Which accounts a STIR block covers and which it does not

The block applies only to a qualified entity (art. 119zg pt 4):

• an individual who is an entrepreneur, including a sole trader (JDG);
• an individual carrying on gainful activity on their own account who is not an entrepreneur;
• a legal person, such as a sp. z o.o.;
• an organisational unit without legal personality to which a statute grants legal capacity.

And only to a qualified entity's account (pt 5): a settlement account under art. 49(1)(1) of the Banking Law — current or auxiliary — a term deposit account, a SKOK member account and the VAT account kept for them. It also covers an account the entity holds jointly (art. 119zv § 5).

A personal current account — rachunek oszczędnościowo-rozliczeniowy, the ordinary ROR — is not in this definition. The Banking Law lists it as a separate type of account in art. 49(1)(3), and the Tax Ordinance definition refers only to point 1. It follows that a business owner who runs the business through a personal account is not subject to a STIR block on that account. This is our reading of two definitions, not case law: if a bank has blocked a personal account citing STIR, have it checked by someone who knows the practice.

A block by the Head of KAS lasts no more than 72 hours

The request names the account number and the period of the block, and that period may not exceed 72 hours (art. 119zv §§ 1–2). On receipt, the bank immediately records the date and time, blocks the account and reports to the Head of KAS the date and time of the block and the balance at that moment (§ 4).

The Head of KAS sends you a notice of the block — promptly after the bank confirms it, covering every request concerning your entity sent up to that point (§ 6). If the company has accounts in several banks, the notice should list all blocked accounts.

During those 72 hours the Head of KAS may narrow the block, and must lift it if it finds that the grounds have ceased (§ 7). There is no appeal against the 72-hour request itself — art. 119zzb lists only the orders issued later. The realistic route in this window is a letter to the Head of KAS with explanations and documents showing the business purpose of the transactions.

Extending the account block to 3 months: the EUR 10,000 condition

The Head of KAS may extend the block by order, for a fixed period of no more than 3 months (art. 119zw § 1). The condition differs from the first block: there must be a justified fear that the entity will not meet an existing or future tax liability, or a third-party tax liability, exceeding the equivalent of EUR 10,000 at the NBP average rate on the last working day of the previous year.

The extension takes effect only if the request reaches the bank during the first block (art. 119zw § 4). If the 72 hours have passed and the bank has not received an extension request, the block lapses and the bank lifts it immediately (art. 119zzc § 1 pt 1 and § 2). That is why the date and time on the notice matter: they decide whether an extension could have worked at all.

The Head of KAS serves the extension order on the entity together with the date and time the request was sent to the bank (art. 119zw § 4a). The order must state the scope, the period, the reasons and information on payments and appeal (§ 2). During the extended block the Head of KAS may change its scope by order, and must lift it if the grounds have ceased (§ 5).

Why the bank will not tell you about a STIR block

The bank does not disclose that it has received the request or blocked the account (art. 119zv § 4a). It will inform you only at your request, and only after the Head of KAS confirms that every block request concerning your accounts has been executed (§ 4b). A helpline agent who says they cannot tell you anything is applying the statute, not evading the question.

It is worth knowing what happens when you make that request: the bank promptly reports to the Head of KAS the date and time of the request and where it came from — the email address, the login IP address, the phone number, the branch or the sender's postal address (§ 4d). Likewise, every instruction to make a transaction from the blocked account goes to the Head of KAS with its date, time and content (§ 4c).

The bank bears no disciplinary, civil, criminal or other liability for executing the block (art. 119zzd). A claim against the bank for blocking the account at the request of the Head of KAS has no basis — the dispute is with the authority, not the bank.

What can still be paid from a blocked company account

A blocked account is not completely closed. The Tax Ordinance provides four kinds of consent, each at your request and by order of the Head of KAS:

1. Employees' wages (art. 119zy § 1 pt 1) — only under employment contracts (umowa o pracę) concluded at least 3 months before the day of the block, together with the income-tax advance and ZUS contributions on that pay. The request is supported by a copy of the payroll and a ZUS document confirming the employee's registration for social insurance under the employment contract. Civil-law contracts (umowa zlecenie) and B2B arrangements are outside this provision.
2. Maintenance or maintenance-type annuity (pt 2) — on presenting the instrument establishing the obligation.
3. Paying tax or customs duty early from the blocked account (art. 119zz § 1 pt 1), and in particularly justified cases, releasing funds (pt 2).
4. Paying tax or customs arrears with interest (art. 119zza) — after a return or correction is filed, after a final decision, or after a decision is made immediately enforceable.

For wages and maintenance the order sets an amount corresponding to the minimum wage (art. 119zy § 2) — in 2026, PLN 4,806 gross. The wording does not settle whether that amount applies per recipient, so we do not assert it here.

Two things work in your favour during the block. Funds on the blocked account are not subject to seizure under a court or administrative enforcement title, save for exceptions in the enforcement rules (art. 54b of the Banking Law). And claims on that account cannot be used as collateral (art. 119zx of the Tax Ordinance).

Appealing a STIR account block: what can be appealed and the deadline

An appeal (zażalenie) lies against orders (art. 119zzb § 1):

• extending the block (art. 119zw § 1) and changing its scope during the extension (§ 5);
• on paying wages and maintenance (art. 119zy § 1);
• on early payment of tax and release of funds (art. 119zz § 1);
• on releasing funds to pay arrears (art. 119zza § 1).

There is no appeal against the first 72-hour request, because it is not an order.

The appeal deadline is 7 days from service of the order — art. 236 § 2 of the Tax Ordinance, applied here by art. 119zzb § 4. The appeal is decided promptly, no later than 7 days from receipt (art. 119zzb § 2). Because the order is issued by the Head of KAS, the same authority decides the appeal — this follows from art. 221 read with art. 239.

The extension order and the order releasing funds for arrears can then be challenged before the voivodeship administrative court, with shortened time limits: the authority forwards the file and its answer within 7 days, and the court decides within 30 days of receiving them (art. 119zzb § 5). The Tax Ordinance does not give the deadline for filing the court complaint itself — that is in the act on proceedings before administrative courts, which we have not read at source.

When a STIR block lapses and when it turns into a seizure

The block lapses (art. 119zzc § 1):

1. when the period in the first request expires, if it was not extended;
2. when the bank executes the Head of KAS's request to lift it;
3. when the period in the extension order expires;
4. on seizure under a security order issued in administrative enforcement or an order securing assets in criminal proceedings — in both cases in connection with the notice of the block and to the extent of the secured amount.

In the first three cases the bank lifts the block in full immediately; in the fourth, for the part not seized (§ 2). The fourth point is the scenario people do not expect: the block does not end with the money released but passes into a protective seizure for the liability or into security in a criminal case. That is a different procedure with different remedies, and this article does not cover its rules.

What to do if the tax authority blocked your account: the steps in order

1. Establish whether it is STIR. Is it the business account or a personal one? Did a letter come from the Head of KAS, or a seizure notice from the head of the tax office? A seizure for arrears is a different matter.
2. Note the date and time of the block from the notice. The 72 hours run from it, and an extension works only if it reaches the bank within that window.
3. Within 72 hours, send explanations to the Head of KAS. The Head of KAS must lift the block if its grounds have ceased. Documents showing the business purpose of the transactions, the counterparties and the source of incoming funds are the main tool in that window.
4. If you have employees on employment contracts, apply for consent to pay wages at once, with the payroll and the ZUS document.
5. If an extension order arrives, count 7 days for the appeal from service.
6. Check the end date of the extension and whether a security order has appeared in the meantime — if so, the block turns into a seizure.

The Head of KAS has blocked your company account and the 72 hours are running — describe your situation today.

Common mistakes with a STIR account block

How to check this yourself

1. Act of 29 August 1997 — Ordynacja podatkowa, consolidated text Dz.U. 2026 poz. 622 (Marshal of the Sejm notice of 22 April 2026), art. 119zg (definitions), art. 119zn (risk analysis), arts 119zv–119zzd (block, extension, payments, appeal, lapse, bank liability) and arts 221, 236 and 239 (appeal authority and deadline).
2. Act of 29 August 1997 — Prawo bankowe, consolidated text Dz.U. 2026 poz. 38, art. 49 (types of account and who may hold a settlement account) and art. 54b (no seizure of funds on an account under a STIR block).
3. The act on proceedings before administrative courts (court complaint deadline), the administrative enforcement rules and the criminal-procedure rules on securing assets. We have not read these acts at source.

Frequently asked questions about a tax authority account block in Poland

When a STIR block needs a representative

A STIR block is a situation where acting alone is usually unwise: the 72-hour window is short, and the consequences hit the company, employees and counterparties at once. Especially when:

• the first 72 hours are running and explanations must reach the Head of KAS in that time;
• an extension order has arrived and the 7 days to appeal are running;
• the block has stopped wage payments;
• a security order or a letter from the prosecutor has appeared alongside the block;
• a personal account has been blocked citing STIR.

Describe your situation in the form below — in English is fine.