A filing with Poland’s Central Register of Beneficial Owners (CRBR) is mandatory for most companies and a number of other registered entities. The online form is free, but identifying the correct beneficial owners, event date and signatories requires an analysis of ownership, control and representation. This guide reflects the system and rules applicable in August 2026.
1. Check the deadline and liability
For entities entered in the National Court Register (KRS) after 10 November 2022, the first filing is due within 14 days of registration and an update within 14 days of the relevant change. Saturdays and Polish statutory holidays are excluded. A constitutive change is counted from its KRS entry; a declaratory change is counted from the actual event, such as a share transfer or appointment of a management-board member.
Failure to file, late filing or data inconsistent with the actual position may lead to a financial penalty of up to PLN 1,000,000. The person submitting the form declares that the information is true and may incur criminal liability for a false statement.
2. Identify the beneficial owners before opening the form
A beneficial owner is every natural person who directly or indirectly controls the entity or can exercise decisive influence over it. Holding more than 25% of shares or voting rights is one indicator, not the only test. Indirect ownership, voting arrangements, parent-company powers and other legal or factual forms of control must also be reviewed.
A senior managing official is a fallback only where the inability to identify the controlling natural persons, or doubts about their identity, has been documented after applying the other tests. Multi-tier and foreign structures should be supported by an ownership chart and registry documents. Our Poland market entry service covers these cases.
3. Prepare the information and supporting documents
You will normally need the entity’s NIP tax number, KRS number, legal name, form and registered office; details of governing-body members or partners entitled to represent it; each beneficial owner’s names, all citizenships, country of residence and PESEL number or date of birth where no PESEL exists; and a clear description of the nature and extent of ownership, voting, control or other rights. Retain the underlying documents in the entity’s records.
4. Open the CRBR portal and select Create
Go to the official CRBR portal and select “Utwórz” in the filing section. The same screen is used to check a submission, download the official receipt (UPO) or import an XML file exported earlier.
5. Enter the NIP and legal form
Enter the reporting entity’s NIP and choose its legal form. NIP identifies the entity in the system. A missing NIP does not remove the statutory duty and should be resolved with the competent tax office before the deadline.
6. Select the filing type and event date
Choose a new filing for the entity’s first entry. Use an update for a later change and link it to the correct event. A correction is used to replace erroneous data in a filing already submitted and should be made promptly after the error is discovered.
The event date is not automatically the date on which the form is completed. For a newly incorporated company it is generally the KRS registration date. For later events determine whether the change becomes effective only on entry in KRS or earlier, for example on execution of a share-transfer agreement or adoption of a resolution with declaratory effect.
7. Complete the entity details
Verify the KRS number, legal name, registered office and other identifiers. The form must reproduce the position as at the event date. If another reportable change occurred before the first filing was sent, two separate filings may be required to show the successive states in chronological order.
8. Add every person and every basis for the entry
Complete the required identification data and role for each person. The same individual may be both a governing-body member entitled to represent the company and a beneficial owner. Record each legal basis separately and describe it clearly enough to show the source of control.
For direct rights, state the relevant shareholding or voting interest. For indirect control, describe the full chain of entities and the percentages or other rights at each level. “Other rights” requires a specific description of the legal or factual circumstances and should not be used as a generic fallback field.
9. Verify representation and obtain the required signatures
The filing must be made by a person entitled to represent the entity. An ordinary attorney-in-fact cannot be appointed solely to submit a CRBR filing. The Ministry of Finance currently confirms that a registered commercial proxy (prokurent) may file where authorised to represent the entity.
The form is signed with a trusted signature or a qualified electronic signature. Where joint representation applies, obtain all signatures required by the representation rules. The system supports multiple trusted signatures, multiple qualified signatures and a combination of both; qualified signatures may require export of the XML file and re-import after signing.
10. Submit the filing and download the UPO
After checking the data, sign the document, select “Wyślij” and confirm the operation. Save the reference number. Use “Sprawdź status zgłoszenia” to download the Urzędowe Poświadczenie Odbioru (UPO), the official acknowledgement of receipt. Saving or signing a draft without completing transmission does not satisfy the duty.
11. Verify the register and retain an audit trail
Once processed, search for the entity by NIP and compare the result with the supporting documents. Keep the XML file, UPO, beneficial-owner analysis, ownership chart and evidence of control. Banks and other obliged institutions compare their own findings with CRBR data, so discrepancies may trigger questions and require an update.
12. Monitor subsequent changes
Changes to shareholders, shareholdings, voting rights, indirect ownership, representation, citizenship or country of residence can trigger an update. Add CRBR to the company’s compliance calendar alongside KRS, tax and accounting deadlines. See our broader post-registration checklist.
For assistance with identifying beneficial owners, preparing the data and coordinating signatures, see our company registration and corporate support service.