Obligation to register the ultimate beneficial owner with the UBO Register

by Joanna Lech and Karolina Sieraczek

26 January 2022

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Below you will find the list of entities which – if they were entered in the National Court Register before 31 October 2021 – are obliged to register their ultimate beneficial owner with the UBO Register (in Polish: CRBR) by 31 January 2022:

1. professional partnerships;
2. foundations;
3. associations subject to the entry in the National Court Register;
4. European Economic Interest Groupings;
5. European companies;
6. co-operatives;
7. European cooperative societies;
8. trusts whose trustees or persons in equivalent positions:

• are resident or have their registered office in Poland or
• establish business relationships or purchase real property in Poland for or on behalf of the trust.

Those of the above-listed entities which were entered in the National Court Register after 30 October 2021 and trusts which meet one of the conditions resulting in the obligation to notify the UBO Register after 30 October 2021 must register their ultimate beneficial owners with the UBO Register within maximum 7 days of entry in the National Court Register or meeting one of the conditions for trusts (as the case may be).
 
In the first step, the entity must identify the ultimate beneficial owner and then it must do the registration. 
 
Failure to register the UBO or to update the information in the UBO Register is punishable with a penalty of up to 1,000,000 zloty.
 
If you have any questions about obligations concerning the UBO Register, you are welcome to contact our experts.