Central Register of Beneficial Owners – 2 months left for data registration

Registration to the Central Register of Beneficial Owners (CRBR) is mandatory for almost all businesses entered in the National Court Register. 13 april 2020 is the deadlinefor registration in the CRBR. For failure to register, companies will face severe penalties.

Central Register of Beneficial Owners – who does it concern?

The Central Register of Beneficial Owners, established by the Anti-Money Laundering and Terrorist Financing Act of 1 March 2018, is an official free ICT database of information on real beneficiaries, i.e. natural persons exercising direct or indirect control over the company.

The obligation to report to the Central Register of Beneficial Owners applies to all companies in the National Court Register except for partnerships and public limited companies.

Registration in the CRBR and updating of data is obligatory for:

• limited liability companies (code 117),
• registered partnerships (code 118),
• limited partnerships (code 120) and limited joint-stock partnerships (code 121),
• joint stock companies, excluding public companies as defined by the provisions of the Act on Public Offering, Conditions Governing the Introduction of Financial Instruments to Organized Trading, and Public Companies of 29 July 2005 (code 1162),
• simple joint stock companies (from 1 March 2021).

Learn more: New remuneration policy in public companies 

Register of Beneficial Owners – what are the deadlines?

Companies established before 13 October 2019 have time to register information only until 13 April 2020. Other entities which entered into the National Court Register after 13 October 2019 have a deadline of 7 days from the date of entry into the National Court Register.

An entity which has not submitted the data to the CRBR within the statutory timeframe shall be subject to a fine of up to PLN 1,000,000 and a person who has entered incorrect data in a notification shall be subject to criminal liability for providing a false statement.

ATTENTION! Information to CRBR shall be reported only by a person authorized to represent the company or a proxy. According to the Act, this task cannot be entrusted to any other person, including an attorney.

Any data change shall be notified to the CRBR within 7 days of the update. Data incorrectly entered shall be amended no later than 3 days after the date of their transmission to the system.

Central Register of Beneficial Owners – the form of registration

Registration to the CRBR shall be made by electronic means only, through the website https://crbr.podatki.gov.pl/ .

Registration to the Central Register of Beneficial Owners is free of charge. It must bear a trusted ePUAP profile or a qualified electronic signature. Persons without a Personal ID number (PESEL) can use the option of a qualified signature without a PESEL compatible with the XAdES algorithm, the format used in all Member

TGC Corporate Lawyers offers support in the area of identification of real beneficiaries and the procedure of their notification to the Central Register of Beneficial Owners.