What is CRBR in Poland?

What is CRBR in Poland?

Sooner or later, all entrepreneurs and legal entities in Poland encounter this abbreviation. In this article, we will explain in detail what CRBR is and why it is necessary.

So, CRBR (Centralny Rejestr Beneficjentów Rzeczywistych) is the Central Register of Beneficial Owners of Enterprises. This register was launched in Poland in 2019.
It is a centralized register and information system created to register and manage the data of all legal entities, sole proprietors, and other entities engaged in economic activities on the territory of Poland. The main purpose of CRBR is to provide public access to up-to-date data on the legal structure and activity status of legal entities, which helps to increase transparency and improve business conditions in the country. CRBR is also the foundation for official inquiries and inspections carried out by various competent authorities in Poland as part of law enforcement and monitoring of economic entities’ activities. It also plays a key role in combating money laundering, preventing criminal organizations from concealing their information within corporate structures.

Who is considered a beneficial owner?

A beneficial owner of a legal entity is a natural person who directly or indirectly owns more than 25% of the company’s capital or has the right to control the company’s activities.
All legal entities registered in Poland must maintain up-to-date information about their beneficial owners. This information is provided as part of the company’s financial reporting.
According to Polish law, a beneficial owner is a person who:

  • Owns more than 25% of shares or equity in the company.
  • Has the right to appoint, employ, or dismiss members of the company’s board or supervisory board.
  • Can exercise any other form of control over the company.

Note: If it is impossible to identify the actual beneficial owner, the data of the individuals holding managerial positions in the company are submitted to the register.

Who is listed in the register?

The register includes all information about natural persons who control the management and activities of a company. This includes company owners, managers, investors, and members of the supervisory board.
The following individuals are listed in the Polish Beneficial Owners Register:

  • Beneficial owners of limited liability companies (Sp. z o.o.).
  • Beneficial owners of joint-stock companies (S.A.).
  • Beneficial owners of simple partnerships (S.k.).
  • Beneficial owners of foundations and trusts.

What information must be provided to the register?

All basic data about a Polish legal entity must be provided to the register:

  • Company name.
  • The legal form of the company.
  • The company’s legal address.
  • The company’s KRS number (from the Polish National Court Register).
  • The company’s tax number (NIP).

Additionally, CRBR requires the following data about the beneficial owners:

  • Full name of the beneficial owners.
  • Citizenship.
  • Country of residence.
  • Individual identification number (PESEL).
  • Information about the size of the shares and rights held by the beneficial owners.

Deadlines for submitting information to the register

After a company is registered with the National Court Register (the date of the company’s registration in Poland’s KRS), and after obtaining NIP and REGON numbers, all the above data about the company and its beneficial owners must be submitted to CRBR within 14 days.
If there are changes in the composition of the company’s founders or directors, these changes must also be reflected in the CRBR register within 14 days.
Important! If a company’s data is not entered into the CRBR, the company will not be able to open a bank account.

How to submit data to CRBR

Only an individual authorized to represent the company—such as a shareholder, board member, or CEO—can submit the necessary data to the register. Delegating this task to other employees is not possible.
The data must be submitted electronically. To submit data to CRBR, you need to use the electronic form available on the website of the Polish Ministry of Finance (crbr.podatki.gov.pl) and sign the form using the trusted profile ePUAP.
Important! A person providing false information to CRBR bears criminal liability.