Changes to PESEL regulations from 2026.

What should be done to protect the company’s management? 

For companies with foreign capital in Poland, efficient management of the management structure is fundamental to operational continuity. Until now, the process of obtaining a PESEL number for foreign board members was a formality that could be handled entirely by a proxy. As of January 1, 2026, the rules of the game are changing drastically. 

On January 1, 2026, the provisions of the Act of September 12, 2025, amending certain acts to verify the right to family benefits for foreigners and on the conditions for assistance to Ukrainian citizens in connection with the armed conflict in that country introduce an obligation for citizens of non-EU/EEA countries to appear in person at the local government office. For companies, this means a review of compliance procedures and the logistics of appointing management board members who do not permanently reside in Poland. 

Why is the PESEL number of a management board member important for the company? 

Although the law does not require a PESEL number for company registration, its absence in practice paralyzes key business processes: 

• Representation and the National Court Register. Without a PESEL number disclosed in the National Court Register, a foreigner has limited possibilities of using IT systems. 

• Financial Reporting. Submitting financial reports electronically via the IT system requires a qualified signature linked to a PESEL number. Failure to do so often hinders timely compliance, potentially resulting in sanctions for management. 

• Taxes and e-Delivery. PESEL is necessary for submitting tax returns and for the effective configuration of e-Delivery, which is becoming standard in communication with offices. 

• Banking Relationships. Banks in Poland are increasingly requiring a PESEL number from persons representing the company, including when opening accounts. 

Key changes from 1 January 2026 

The new Article 18, Section 1a of the Act puts an end to the “remote” assignment of PESEL numbers by law firms to persons outside a specific group of countries, those outside Europe. 

1. No more power of attorney (for the chosen ones) 

Until now, a copy of the passport and a signed power of attorney were sufficient. From 2026, foreigners must physically appear at a Polish office. 

2. Who is subject to the obligation to appear in person? 

The change primarily affects management staff outside: 

• European Union (EU), 

• European Economic Area (EFTA/EEA), 

• Switzerland and Great Britain (with some reservations). 

If your board member comes from, for example, the USA, China, India or South American countries, his visit to Poland will become mandatory. 

3. Logistics and language barriers 

A personal visit to the office involves more than just travel costs. If a board member does not speak Polish fluently, the assistance of a sworn translator is necessary during the procedure. 

Risks for companies with foreign capital 

These changes should be factored into the budget and schedule planning for 2026. Lack of preparation may result in: 

• Blocking signatures on contracts at key moments. 

• Delays in the National Court Register, which affects the company’s credibility towards foreign contractors. 

• The fragmentation of services, searching for a translator, organizing logistics and legal advice from various suppliers, which increases costs and the risk of error. 

Recommendations: how to prepare your company? 

To avoid administrative paralysis and ensure 100% legality of representation, it is worth considering the following steps: 

1. Strategic Legal Partner. Instead of using 3-5 different law firms, choose one partner who combines corporate law, immigration law, and corporate services. Ask about our service.  

2. Revision of the composition of the management board. In some cases, it is worth considering appointing at least one person with EU citizenship to the management board, which will facilitate ongoing communication with Polish authorities and the operation of Polish digital systems. 

3. Integrated process. Combine PESEL assignment with Central Register of Beneficial Owners (CRBR) update and qualified signature configuration in one procedure. 

How can we help your company? 

As a law firm specializing in international business services, we understand that your time is crucial to your company’s operational continuity. We provide comprehensive support: from verifying the legal basis, through the logistics of the visit (including a sworn translator), to registration in the National Court Register (KRS) and the Central Register of Beneficial Owners (CRBR). 

Instead of managing multiple legal service providers, focus on a single point of contact and complete process transparency. TGC offers a comprehensive solution that eliminates the risk of decision-making paralysis in your company. 

Our services include, among others: 

• Ongoing legal advice 

• Support in implementing changes such as: 

• Changes in the company’s bodies 

• Changes in the composition of the company’s shareholders 

• Changes to the articles of association 

• Regulating the mutual rights and obligations of partners 

• Representation at shareholders’ meetings/partnership meetings 

• E-Delivery – electronic delivery services for your company. 

Don’t let changing regulations stall your business. 

Learn more about corporate services at TGC