Every new company has 14 days to report its beneficial owners, and every change of shareholders means another filing. We explain who to register and what neglect can cost you.
The Central Register of Beneficial Owners (CRBR) is a public database in which companies identify the persons who actually control them. The obligation stems from anti-money laundering legislation and applies to almost all companies — including small, single-shareholder limited liability companies (sp. z o.o.).
Who is a beneficial owner
Most often this is a natural person who holds more than 25% of the shares or votes or exercises control in another way. If no such person can be identified, the members of the management board are registered.
Deadlines
- 14 days from the company's entry in the KRS (National Court Register) — the first filing,
- 14 days from each change — e.g. a sale of shares, a change of shareholders or of their details.
Filings are made electronically and are signed by a person authorised to represent the company.
Penalties
Failure to file or providing false data carries a financial penalty of up to PLN 1 million, and knowingly providing false information can also lead to criminal liability. Banks and other institutions increasingly compare CRBR data with the actual situation and suspend services when they find discrepancies.
How we handle it
When setting up a company, we make the CRBR filing together with the other formalities, and as part of ongoing accounting services we remind you to update it after every change in the KRS.
