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Polish UBO register – changes required


by Marianna Kroll

22 September 2021


Another round of legislative changes to the Polish Register of Ultimate Beneficial Owners (UBO Register, or CRBR in Polish) will come into force on 31 October 2021.

Verification of data in the UBO Register

The most important change for enterprises is the introduction of the verification mechanism of data disclosed in the UBO Register. Obliged institutions (e.g. banks) will have to: check their clients' data disclosed in the UBO Register, verify and list discrepancies in the data in the Register and report them to competent authorities for clarification.

New obligations for enterprises

This means that if the UBO Register is missing up-to-date information, an obliged institution, e.g. a bank, will have to notify the competent authorities, and this may lead to a fine. That is why enterprises have to remember about keeping their data disclosed in the UBO Register (e.g. details of management board members or address) up to date. The registration alone is not enough.
The amended statute also changes the penalties for non-compliance with the UBO registration obligations. Penalties will be imposed not only for a failure to enter an entity in the UBO Register on time, but also for not updating the disclosed data on time or for reporting untrue information. A non-compliance with the above obligations is subject to a fine of up to 1,000,000 zloty.
Also the list of entities obliged to register and update their details in the UBO Register will be extended to include, among others, European companies (SE), professional partnerships and trusts.


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Karolina Sieraczek

Attorney at law (Poland)

Associate Partner

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