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Central Register of Beneficial Owners

Central Register of Beneficial Owners

On 13 October 2019, the obligation to register in the Central Register of Beneficial Owners (CRBO) entered into force. The CRBO is a database where information on natural persons who directly or indirectly control a company/partnership (the so-called beneficial owners) is collected and processed.

Legal basis: Act of 1 March 2018 on counteracting money laundering and terrorism financing.

For the sake of convenience of the Bank’s Clients, below we have summarised key information about the new obligation.

Who does it apply to?

The following entities will be required to apply for an entry in the register:

  • general partnerships,
  • limited partnerships,
  • limited joint-stock partnerships,
  • limited liability companies,
  • joint-stock company (except for public companies).

What does the new obligation consist in?

  • A person authorised to represent a company/partnership will be required to apply for an entry in the Register, providing identification data of the beneficial owner, such as:
    1. name and surname,
    2. citizenship,
    3. country of residence,
    4. personal ID No (PESEL) / date of birth – in the case of individuals without a personal ID No,
    5. information on the volume and nature of interest or the rights vested in the beneficial owner.
  • The application will be filed electronically and the applicant will have to sign it with an electronic signature or certify with their ePUAP trusted profile.

When should an entry be made?

The regulations entered into force on 13.10.2019.

Companies/partnerships
entered in the National
Court Register before that
date have 9 months for
filing an application – by
13.07.2020.

Companies/partnerships
established after that date
have only 7 days for filing
an application.

Once a company/partnership has applied for an entry in the CRBO, it should update its details in the CRBO within 7 days from the occurrence of a change.

Correct indication of the beneficial owner may be difficult in the case of an extensive ownership structure. Enclosed please find a short guide on how to determine Beneficial Owner.