On 13 October 2019, the Central Register of Beneficial Owners (CRBO) will start to operate. From this date on, the existing entities will have 6 months to fulfil their statutory reporting obligations.
CRBO is an ICT system to be used to process information about beneficial owners of companies and partnerships. The register will be public. The procedure for filing notifications to the register has been laid down by the Minister of Finance in the Regulation of 16 May 2018 and, according to it, notifications will be submitted through a link on the Public Information Bulletin’s website for the Ministry of Finance.
The act defines the beneficial owner as:
Entities obliged to submit and update information about beneficial owners will include:
Persons responsible for the submission of the required identification details to the register, will be the persons authorized to represent an entity.
Such information should be submitted to the register free of charge by means of electronic communication, not later than within 7 days from company’s entry in the National Court Register, and in the case of a change of already provided information – within 7 days from the change.
Entities already entered in the National Court Register at the time of register opening will be obliged to submit the required information within 6 months following the effective date of the regulations concerning the register (namely until 13 April 2020).
The notification will have to include a statement of the person submitting information to the register on its being true and correct. The person submitting information about beneficial owners will be liable for damage caused as a result of provision of false data. Entities obliged to submit information which fail to perform this obligation within the statutory time limit may be subject to a fine of up to PLN 1,000,000.
The procedure for filing requests to provide information on beneficial owners has been laid down by the Minister of Finance in a separate Regulation of 16 May 2018 which will come into force on 13 October 2019. Information about beneficial owners collected in the register will be made available free of charge.
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