The Central Register of Beneficial Owners, CRBR (Centralny Rejestr Beneficjentów Rzeczywistych), has been operating in Poland since October 2019. If you run a commercial company here, this is one of the compliance obligations that’s easy to overlook and expensive to miss. Here’s exactly who must register, by when, and what the penalties look like in 2026.

What is CRBR

CRBR is a free, electronic, public register maintained by the Ministry of Finance, created to implement the EU’s anti-money-laundering (AML) framework, specifically the requirement to disclose the individuals who ultimately own or control legal entities operating in a member state. It stores data on the so-called ultimate beneficiaries of companies: natural persons who directly or indirectly control the entity. All data collected in CRBR is public and searchable at podatki.gov.pl, free of charge.

The legal basis is the Act of March 1, 2018 on Counteracting Money Laundering and Terrorist Financing (the “AML Act”), which implements EU Directive 2015/849 and its subsequent amendments.

Who has to register with CRBR

CRBR obligations apply to entities registered in the National Court Register (KRS), primarily commercial companies:

  • limited liability companies (Sp. z o.o.);
  • joint-stock companies (S.A.), except public companies listed on a regulated market;
  • simple joint-stock companies (P.S.A.);
  • limited partnerships (spółka komandytowa);
  • limited joint-stock partnerships (spółka komandytowo-akcyjna);
  • general partnerships (spółka jawna) and professional partnerships (spółka partnerska);
  • cooperatives, foundations and associations that are subject to KRS registration, European companies, European cooperatives, and certain trusts with a sufficient link to Poland.

Sole proprietors (JDG) are not covered by CRBR. A JDG is registered in CEIDG, not KRS, and has no separate legal personality from its owner: the entrepreneur and the beneficial owner are simply the same person. Banks and other AML-obliged institutions still have to identify you as the beneficial owner of your own business when you open an account, but there’s no CRBR filing to make. If you later convert your JDG into a Sp. z o.o., the newly registered company becomes obliged to file with CRBR from the moment it’s entered into KRS.

Foreign companies operating in Poland solely through a registered branch (oddział) are likewise outside CRBR’s scope.

Identifying the beneficial owner in a company ownership structureIdentifying the beneficial owner in a company ownership structure

Deadlines, 14 working days, not 7

This is the single most important update to this article: the deadline changed from 7 to 14 working days back on November 10, 2022. A lot of older guides, including earlier versions of this article, still quote 7 days, which is no longer correct.

Under the current Article 60 of the AML Act:

  • a newly registered entity must file its initial beneficial-owner data within 14 working days of its KRS registration;
  • any change to previously filed data (new shareholder, changed shareholding percentage, new management board member, etc.) must be reported within 14 working days of the change, counted from the KRS entry date for changes that require one, or from the date the change actually occurred for changes that don’t;
  • Saturdays and public holidays don’t count toward the 14 days.

Entities registered in KRS before October 13, 2019 had a one-off transitional deadline (July 13, 2020) to file for the first time; that deadline has long since passed and is only relevant historically.

Who is a “beneficial owner”

Under Article 2(2)(1) of the AML Act, a beneficial owner (“beneficjent rzeczywisty”) is any natural person who directly or indirectly exercises control over the entity through legal or factual means, or for whose benefit business relations are established. In practice, this is most often identified through ownership or voting thresholds:

  • a natural person holding more than 25% of shares or units in the entity;
  • a natural person holding more than 25% of voting rights in the entity’s governing body;
  • a natural person exercising control through a chain of other legal entities that jointly meet the above thresholds;
  • a natural person exercising control through means other than ownership, for example, veto rights, shareholder agreements, or a parent-company relationship under accounting law;
  • if none of the above can be identified, the natural persons holding senior management positions (fallback rule).

Note: the EU’s new AML Regulation will refine this definition further from July 2027 onward, but as of 2026 the Polish 25% threshold above is still the operative rule.

How to register and what happens if you don’t

Notifications can only be submitted electronically, through the podatki.gov.pl portal, and must be signed by a person authorized to represent the entity, using a qualified electronic signature or a verified ePUAP trusted profile. There’s no paper filing option and no fee to submit.

Failing to file, failing to update, or filing false information exposes the entity to an administrative fine of up to PLN 1,000,000. This maximum penalty is unchanged and remains fully in force in 2026.

A newer development worth flagging: since the deadline extension of November 2022, beneficial owners themselves now have a legal duty to supply the entity with the information and documents needed for a timely CRBR filing. A beneficial owner who withholds that information, causing the entity to miss the deadline or file incorrect data, faces a separate fine of up to PLN 50,000.

Bibliography and Legal Basis

Need help figuring out who your company’s beneficial owner is, or getting your CRBR filing done correctly? Book a free consultation with our team.

Legal status as of: September 25, 2026.

Author: Walery Kusznirski, in-house legal practitioner at MojaFirma.

This article is for informational purposes only and does not constitute legal advice. Every situation depends on the specific corporate structure and individual circumstances. If something about your own situation isn’t quite clear, feel free to book a free consultation with our team.