Notification to the Register of Beneficial Owners – an obligation after company registration and after changes in the National Court Register After a company is registered with the National Court Register (KRS) and after any change in the company’s ownership structure or bodies, it is necessary to submit a notification to the Central Register of Beneficial Owners (CRBR). This is an obligation that many entrepreneurs forget about, and failure to do so can result in serious financial consequences.  

What is CRBR? 

The Central Register of Beneficial Owners is a public register maintained by the Ministry of Finance. It collects information on beneficial owners, i.e. individuals who exercise actual control over a company. The purpose of this registry is to increase transparency of ownership structures and to counter money laundering and terrorist financing.  

When should a notification be made to the CRBR? 

According to current regulations, after the amendment of the AML/CFT Law, a business has 14 working days to report data to the CRBR. This deadline applies to both:  

– notification of a newly registered company, as well as
– updating data in case of changes (e.g., changes in shareholders, board members, shareholding structure). 

In the case of changes, the deadline is counted from the date of the event affecting the data of the real beneficiary (in the case of declaratory changes) or from the date of entry in the KRS (in the case of constitutive changes). Note that the deadline is calculated in working days – so Saturdays, Sundays and holidays do not count.  

How to submit an application? 

The application is made only electronically, via the Ministry of Finance website: https://crbr.podatki.gov.pl. A qualified signature or a trusted profile of a person authorized to represent the company (usually a member of the board of directors) is required to submit the application. The form should contain, among other things, the data of the real beneficiary: name, surname, citizenship, PESEL number or date of birth, as well as information about participation or influence on the company’s activities.  

What are the consequences of not reporting? 

Failure to report to the CRBR or failure to do so in a timely manner may result in a fine of up to PLN 1,000,000. In addition, a real beneficiary who fails to provide the required information or provides data that is inconsistent with reality may also be penalized.