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Poland Alert - The Central Ultimate Beneficial Owner Register – key information – probable extension of the registration deadline

02 April 2020
We would like to bring to your attention the issue of the mandatory registration of the ultimate beneficial owner (UBO). The former statutory register date was April 13, 2020, however this deadline will most likely be extended until July 1, 2020. 

What is the UBO Registry?

The Central Ultimate Beneficial Owner Register (Centralny Rejestr Beneficjentów Rzeczywistych) was introduced by the Polish Anti-Money Laundering and Anti-Terrorist Financing Act of 1 March 2018 . The aim of this register is to process information about the "real" owners of Polish partnerships and companies.

Which companies are subject to registration?

The following Polish entities are obliged to notify of (and update) information on their beneficial owners:

  • general partnerships;
  • limited partnerships;
  • limited joint-stock partnerships;
  • limited liability companies;
  • joint-stock companies, excluding publicly listed companies.

Who is the Beneficial Owner?

The beneficial owner is a natural person(s) who directly or indirectly exercises control over the entity due to legal or factual circumstances.


Companies which fail to submit information to the UBO Registry by the deadline indicated can be fined up to PLN 1,000,000.

Submitting false data to the UBO Registry may also trigger the criminal liability of representatives of the given entity. 

What data should be registered in the UBO Registry?

The information to be mandatorily reported to the UBO Registry is the following:

  • identification data of the company (name, organisational form, registered office, National Court Register number, NIP number);
  • identification data of the UBO and the member of a management body or a shareholder authorised to represent the company (name and surname, citizenship, country of residence, PESEL number or date of birth - for persons without a PESEL, information on the size and nature of the share(s) or rights held by the UBO in the entity).


The application must be signed with a qualified e-signature or signature, confirmed by the trusted e-PUAP profile. This can be done only by members of the management board (proxies or agents are excluded), and submitted only through the official website of the Ministry of Finance.

The application is free of charge.

How can we help?

We can offer our support in the identification process of the UBO in a given company as well as assist with the registration process of the UBO, which should be done through a dedicated application available on the website run by the Minister of Finance.

Tax Team
DWF Poland

To read this update in Polish, download our PDF >

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