Last Updated: 09.07.2026
What is the Central Register of Beneficial Owners in Poland?
The Central Register of Beneficial Owners (CRBR) is a public registry of individuals who exercise control directly or indirectly over companies entered in the National Court Register.
Its primary purpose is to fulfill the obligations arising from the AML Act (Counteracting Money Laundering and Terrorist Financing).
Public and free access to the registry allows for the quick identification of individuals managing companies entered in the National Court Register. This article covers the functioning of the CRBR, its significance, obligations related to the registry, and sanctions for non-compliance.
Origins and Legal Basis of the CRBR
The CRBR was established as a result of the implementation of EU regulations, in particular the 4th and 5th AML Directives, which require member states to create mechanisms for identifying the persons who actually control companies. The registry serves as a tool for tracking the ownership structure of companies, which is particularly important in combating phenomena such as money laundering, tax evasion, corruption, and the financing of terrorist activities.
In Poland, the CRBR is maintained by the Ministry of Finance, and access to the registry is public, meaning that anyone can check the data contained in the system without having to justify the purpose of their action. This structure promotes greater economic transparency.
Who Must Register with the CRBR in Poland?
Entities operating within the territory of Poland are subject to registration with the CRBR in the case of entities listed in the AML Act. Among those required to register are:
- general partnerships;
- limited partnerships;
- limited joint-stock partnerships;
- limited liability companies;
- simple joint-stock companies;
- joint-stock companies, with the exception of public companies;
- professional partnerships;
- European Economic Interest Groupings;
- European companies;
- cooperatives;
- European cooperatives;
- associations subject to registration in the National Court Register (KRS);
- foundations;
- trusts; and other entities subject to the obligation to disclose beneficial owners under specific regulations.
Who is an Ultimate Beneficial Owner under Polish AML Law?
A beneficial owner (UBO) is a natural person who exercises actual control over a given entity.
The Anti-Money Laundering Act defines a beneficial owner in detail.The ultimate beneficial owner is a natural person who is able to exercise decisive influence over the actions or decisions of an entity, whether directly or indirectly. The Anti-Money Laundering Act defines a beneficial owner in detail. The concept of beneficial ownership is discussed in more detail in our separate article, available here.
CRBR Reporting Obligations for Polish Companies
New business entities must register with the CRBR within 14 business days of the entity’s entry into the National Court Register (KRS). In the first filing, the entity should report information that is accurate as of the date of entry in the National Court Register. In the event of a change to the data reported to the CRBR, the change must be reported within 14 days of the change occurring. The registrant’s obligations include:
- Identification of beneficial owners.
- Verification of the collected data.
- Submission of data to the registry via an electronic system.
It should be noted that data submission may take place exclusively via an electronic system.
What Information Must Be Reported to the CRBR?
The CRBR registration covers two groups:
- data of the entity to which the registration pertains:
- name (business name)
- legal form (e.g., limited joint-stock partnership)
- registered office
- KRS number
- NIP number
- details of the beneficial owner:
- first and last name of the beneficial owner,
- citizenship (or nationalities),
- PESEL number (or date of birth if no PESEL number is available),
- address and country of residence,
- the size and nature of the shares held or rights vested.
Penalties for Failure to Report Beneficial Owners to the CRBR
Failure to report data to the CRBR within 14 days, failure to update it correctly within the same period, or providing data inconsistent with the facts, entails serious financial consequences, as penalties may reach a fine of up to 1 million zlotys.
In addition, entities may be held civilly liable for losses resulting from failure to report, which is particularly important in dealings with business partners or financial institutions.
The same risk may arise where false or incomplete information is submitted in order to avoid disclosure of the ultimate beneficial owner or the actual ownership structure of the entity.
Who Can Submit a CRBR Filing?
Reports to the Central Register of Beneficial Owners may only be filed by a person authorized to represent the entity, in accordance with the entity’s rules of representation.
Persons making the registration are responsible for the accuracy of the information provided, taking into account the risk of criminal liability for providing false data.
It is worth noting that a registration with the CRBR cannot be made through a proxy.
How to Submit a CRBR Registration in Poland?
The registration process takes place exclusively online on the CRBR registry website. After logging into the system, you must complete the registration form – enter the entity’s tax identification number (NIP) and select its organizational form.
Next, you must specify the date of registration. The next step is to complete the details of the entity to which the registration applies, i.e., the KRS number, name, and current registered office address, as well as the details of the beneficial owner(s). Finally, the registration must be signed electronically, i.e., using a qualified electronic signature or a trusted ePUAP profile.
In practice, the filing should be reviewed before submission in order to ensure that the data concerning the entity, its representatives and their beneficial owners is complete and consistent with the actual legal and ownership structure.
Qualified Electronic Signature for CRBR Filing
A Qualified Electronic Signature (QES) ensures full compliance with EU and Polish regulations; the legal validity of the signature throughout the EU; security; the ability to sign documents remotely and enter into contracts with counterparties; and savings in time and resources. More information about QES can be found in our article here.
ePUAP Trusted Profile and CRBR Registration
ePUAP, or the Electronic Public Administration Services Platform, is a system that allows citizens and businesses to handle official matters online without having to visit government offices in person. Thanks to ePUAP, you can submit applications, sign documents using a trusted profile, and receive official correspondence in electronic form. This platform simplifies contact with the administration, saving time and making it more convenient to use public services. It should be emphasized, however, that a PESEL number is required to create an account on the ePUAP platform and obtain a trusted profile. It is necessary to confirm the user’s identity in public administration systems that use ePUAP.
Therefore, for a foreign entrepreneur, obtaining a QES-a qualified electronic signature-may be a better option. A QES is a form of signature that has the same legal validity as a handwritten signature in EU countries. QES is commonly used in documents requiring particular reliability, such as contracts, official applications, or international transactions.
Benefits of the Central Register of Beneficial Owners
The introduction of the CRBR brings many benefits, both for the public and private sectors. The most important include:
- Increased transparency – the ability for counterparties and financial institutions to verify beneficial owners.
- Reduction of financial fraud – making it more difficult to hide assets or engage in illegal activities.
- Increased market confidence – especially among foreign investors, who can assess the credibility of their business partners.
Practical Challenges in Identifying Beneficial Owners
Although the CRBR represents a significant step toward transparency, its operation involves certain challenges. These include:
- The complexity of identifying beneficial owners in multi-tiered capital structures.
- Potential issues with interpreting the definition of a beneficial owner.
- Consequences related to the possible disclosure of sensitive personal data.
Legal Assistance with CRBR Filing and Beneficial Ownership Compliance in Poland
CRBR filing may require careful legal analysis of the ownership structure, representation rules and the status of the ultimate beneficial owner. This may be particularly relevant in the case of foreign entrepreneurs, cross-border structures, multi-tier ownership arrangements or doubts regarding the person who should be disclosed in the register.
A Polish law firm can support entrepreneurs in identifying beneficial owners, preparing the required data, submitting or updating CRBR filings, and assessing compliance with Polish AML regulations.
Summary
The Central Register of Beneficial Owners is an important tool supporting the prevention of money laundering and terrorist financing. It helps identify the natural persons who ultimately control a company or another legal person and promotes greater transparency and security in business.
In practice, determining who should be the beneficial owner may require an analysis of the ownership structure, voting rights and control mechanisms within the entity. This is particularly relevant in the case of multi-tier structures in which a natural person may exercise control through another legal person. Where it is not possible to determine the ultimate beneficial owner, or where there are doubts as to the identity of the relevant persons, the rules set out in the AML Act may require indicating a person holding a senior management position, such as a management board member.
Although the CRBR is a statutory requirement, it may also help raise compliance standards in the Polish economy. To avoid problems related to changing regulations and the correct interpretation of the Act, it is advisable to seek the assistance of a law firm whose experts can support the identification of beneficial owners, the submission and updating of CRBR data, and the assessment of reporting obligations. This step can reduce legal risk and facilitate ongoing regulatory compliance.
