Financial Crime World

Poland Introduces Beneficial Ownership Transparency Requirements

Poland has taken a significant step towards boosting transparency and combating financial crimes by introducing mandatory beneficial ownership disclosure requirements for certain companies and partnerships registered in the country.

What You Need to Know

  • As of October 13, 2019, all entities subject to registration must submit information on their ultimate beneficial owners (UBOs) to the Central Register of Ultimate Beneficiaries (CRUB).
  • The deadline for existing entities was initially set for April 13, 2020, but has since been extended to July 13, 2020, due to the COVID-19 pandemic.
  • Newly incorporated entities have a seven-day window from their entry into the National Court Register (NCR) to register their UBOs.

Registration Requirements

To comply with the regulations, companies must submit certain data to the CRUB, including:

  • Business name
  • Organizational form
  • Seat address
  • National Court Register number
  • Tax Identification Number (NIP)
  • Information on the UBO/representative

The data can only be entered by authorized representatives of the company, who are responsible for ensuring its accuracy.

Consequences of Non-Compliance

Failure to comply with the regulations may result in penalties up to PLN 1 million (approximately EUR 230,000) or criminal liability for submitting untrue data. Representatives of registered entities are also liable for damages caused by failure to submit data within the statutory deadline or updating it after changes.

Assistance with Compliance

To assist companies with compliance, experts offer a range of services, including:

  • Comprehensive reviews of ownership structures
  • Drafting reports identifying UBOs
  • Online support during registration on the dedicated CRUB website

The Central Register of Ultimate Beneficiaries (CRUB) is an electronic database maintained by the Minister of Finance and contains information on the UBOs of registered entities. This registry aims to enhance national financial security and reduce the risk of money laundering and terrorist financing by providing access to ownership structures.