The Ultimate Beneficiary Owner Register (UBO Register)

The Ultimate Beneficiary Owner Register (UBO Register) has been launched in Poland on October 13, 2019. It obliges all Polish partnerships and companies registered in the Polish National Court Register to provide information about their ultimate beneficial owners.

All companies from National Court Register from are obliged from the date of October 13, 2019 till April 13, 2020 to register their beneficial owner.

An application must be signed with qualified e-signature or a signature, confirmed by the trusted profile e-PUAP by the authorized person to represent the entity, and submitted only through the official website of the Ministry of Finance https://podatki.gov.pl/crbr/.

Companies which have not fulfilled their obligation to submit the required information to the UBO Register within the deadlines specified above, may be fined up to PLN 1,000,000,000.

The launch of the Central register of beneficial owners is a result of the implementation of the EU Directive on preventing the use of the financial system for money laundering or terrorist financing.

Under the Act on Counteracting Money Laundering and Terrorist Financing, beneficial owners are individuals who provide direct or indirect control of the company through their rights based on legal or factual circumstances and documentation.

Which information needs to be provided?

The following information should be provided as part of the notification to the register:

1. Company data:

• name of the companytype of organization,

• registered office,

• National Court Register (KRS) number,

• taxpayer identification number (NIP).

2. Personal data of the beneficial owner, governing body members or partner authorized to represent the company:

• name and surname,

• citizenship,

• country of residence,

• Universal Electronic System for Civil Registration Number (PESEL) or date of birth,

• scope and nature of the participation or on the rights of the beneficial owner.

Companies required to report information on the CRBR are the following:

• General partnerships,

• Limited partnerships,

• Limited joint-stock partnerships,

• Limited liability companies,

• Joint-stock companies (excluding public companies).

The information will have to be submitted by a person authorized to represent the obliged entity via the Register’s website.

Companies registered in the National Court Register before the effective date of the regulations concerning the CRBR (i.e. before October 13, 2019) are obliged to report information on beneficial owners by 13 April 2020.

All companies registered afret registered in the National Court Register after October 13, 2019 are obliged to notify the data no later than within 7 days from the date of entry into the National Court Register.

In the case of updating the information provided in the CRBR, the deadline for submitting updates will be 7 days from the date of their change.

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