Central Register of Beneficial Owners (CRBR) has been active in Poland since October 13, 2019, launched by the Ministry of Finance. In this article, we explain what the register is for, who is obligated to submit information, and what risks come with non-compliance. 

What is the CRBR?

The CRBR is an online, publicly accessible register maintained by the Polish Ministry of Finance, available at: https://www.podatki.gov.pl/crbr/. It stores information about beneficial owners – individuals who have real control over companies and entities registered in Poland’s National Court Register (KRS). 
Its core purpose is to prevent money laundering and terrorist financing by increasing ownership transparency and making it harder to hide behind complex corporate structures. 

Which entities are required to register to CRBR?

The obligation to register with the CRBR certainly applies to: 

• Partnerships: general, professional, limited, and limited joint-stock partnerships; 

• Capital companies: limited liability companies, simple joint-stock companies, and joint-stock companies (excluding listed/public companies); 

• European companies and European Economic Interest Groupings (EEIGs); 

• Cooperatives, including housing cooperatives and European cooperatives; 

• Foundations; 

• Registered associations; 

• Trusts, if their trustees or equivalent persons reside, operate, or own real estate in Poland. 

Foreign entities that only have a registered branch in Poland do not have to submit an application to the CRBR. 

Who is a beneficial owner?

According to the Polish Anti-Money Laundering (AML) Act, a beneficial owner is any natural person who directly or indirectly controls a company or other legal entity, based on legal or factual rights that allow them to make key decisions or influence operations. 

This includes: 

• Individuals with direct control (e.g. holding a majority of shares or voting rights); 

• Those with indirect control (e.g. controlling a company through another entity); 

• Shareholders with more than 25% ownership in the company. 

If no specific person can be identified (e.g., due to dispersed shareholders), the senior management (e.g. Company President or CEO) must be reported instead. 

Meanwhile, in foundations, the beneficial owners are usually founders or individuals who hold controlling powers. Moreover, for associations, board members are considered beneficial owners for registration purposes. 

What data must be submitted to CRBR?

Three types of information must be included in a CRBR application: 

1. Entity data: name, legal form, registered office, KRS number, and tax ID (NIP); 

2. Beneficial owner data: full name, nationality, country of residence, PESEL number (or date of birth if PESEL is unavailable), and the nature of the control or rights held; 

3. Data of the reporting person, such as a management board member (same categories of data as above). 

Deadlines for submission CRBR

• A new entity must submit its CRBR application within 7 days of being entered into the KRS. 

• Any change of data must also be updated in the register within 7 days of the change occurring. 

• Companies that existed before the CRBR law came into force (before October 13, 2019) were required to submit their entry by July 13, 2020. 

How to submit your application to CRBR?

The registration can be completed only online, via the Ministry of Finance’s web form. Paper-based submissions are not accepted. 

To finalize the process, the form must be signed with either: 

• a Trusted Profile (ePUAP), or 

• a qualified electronic signature. 

Who can sign the CRBR application?

Only persons authorized to represent the entity, such as Management Board members or proxies, may submit the application. 
It is not possible to delegate this task to an attorney or external representative. 

What are the penalties for non-compliance?

Failure to register, update, or provide accurate data in the CRBR may lead to severe financial penalties. The AML Act allows authorities to impose an administrative fine of up to 1 million PLN. Therefore, registering with the CRBR is a legal obligation and should not be overlooked. 

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Text based on: https://www.gov.pl/web/finanse/centralny-rejestr-beneficjentow-rzeczywistych