New entities obliged to report to the CRBR

On October 31, the list of entities that are required to report information concerning beneficial owners to the Central Register of Beneficial Owners was extended. The new obligations involve business entities such as cooperatives, partnerships, foundations and associations and more.

For more detailed information regarding Central Register of Beneficial Owners, please check here.

What is CRBR and who is a beneficial owner?

The Central Register of Beneficial Owners (CRBR) is an electronic system maintained by the Ministry of Finance that collects data regarding beneficial owners. These are natural persons who have direct control over economic entities, including commercial law companies.

Have you got any problems with assigning a beneficial owner?

If the beneficial owner cannot be clearly identified when reporting to the CRBR system, the person or persons holding a senior management position must be reported instead.

Who must report the beneficiaries to the CRBR system starting with October 31, 2021?

The previously existing list of entities required to report to the CRBR system has been expanded to include:

professional partnership,
European Economic Interest Groups,
European Companies,
cooperatives,
European Cooperative Societies,
associations subject to registration into the National Court Register,
foundations,
trusts, whose trustees or persons in equivalent positions have their place of residence or registered office in the territory of the Republic of Poland or establish business relations or acquire real estate in the territory of the Republic of Poland in the name or on behalf of the trust.

By when should I report a beneficiary to the CRBR system?

The aforementioned entities which are registered into the National Court Register system before October 31, 2021 are required to report the beneficial owners to the CRBR system by January 31, 2022 at the latest.
Alternatively, the entities that are registered into the National Court Register after October 30, 2021, the deadline for filing a notification with the CRBR system is 7 days from obtaining entry into the National Court Register.
These deadlines should be applied accordingly provided that the conditions set out above are also met for trusts.

Penalty for failure to report a beneficial owner

Any failure to report a beneficial owner within the specified deadlines and for providing false data is punishable by a fine of up to 1 million PLN.

How to report a beneficial owner?

Beneficial owners can be reported free of charge through the website of the Central Register of Beneficial Owners.

The notification of reporting a beneficial owner can be signed using a trusted profile or a qualified electronic signature.

Important note!

Notification to the CRBR may be reported only by a person appointed to represent the business entity on the basis of the articles of association.

It cannot be notified by a proxy.

You need help?

Contact us, our specialist will be happy to provide you with more information:

[email protected]

Legal basis:
– Article 58 of the Act of 1.03.2018 regarding prevention of money laundering and financing of terrorism (Journal of Laws of 2021, item 1132 as amended).