Poland maintains a publicly accessible beneficial ownership register. The Central Register of Beneficial Owners — Centralny Rejestr Beneficjentów Rzeczywistych, CRBR — was established under the AML Act of 1 March 2018 and has been operational since October 2019. It records the natural persons who ultimately control Polish legal entities. Control is the operative concept: the register is not a list of shareholders. It is a list of the individuals whom the reporting entity has identified as exercising ultimate control.
This register is public and free of charge. What you are paying for is the removed path: registration, national identifier, language, electronic signature, declaration of legitimate interest.
What the register showsNatural persons identified as beneficial owners of Polish legal entities, with name, nationality, country of residence, date of birth, PESEL number (where applicable), and the nature and extent of the control exercised. Source: CRBR (crbr.podatki.gov.pl) · verified 2026-09-15 Access conditionPublic access, no registration required, no fee charged by the register. Source: Art. 67 AML Act 2018 (as amended) · verified 2026-09-15 Reporting obligationCovers spółki jawne, spółki komandytowe, spółki komandytowo-akcyjne, spółki z ograniczoną odpowiedzialnością, spółki akcyjne, and certain other entities. Source: Art. 58 AML Act 2018 · verified 2026-09-15 What the register does not showThe register does not display the underlying ownership chain, the intermediate holding structure, or the documentary basis for the declaration. Source: CRBR technical specification · verified 2026-09-15Who must report and what they must declare
The AML Act imposes a reporting obligation on a defined list of entity types. The obligation falls on the entity itself, not on the beneficial owner. The entity's management board submits the declaration under personal liability for its accuracy.
The declaration must identify every natural person who meets at least one of the following criteria: holds, directly or indirectly, more than 25 percent of shares or voting rights; exercises control through other means; or, where no natural person can be identified under those criteria, the member of the senior management body.
The 25-percent threshold is a floor, not a ceiling. An entity may declare a person controlling a smaller stake if that person exercises effective control through contractual or structural means. The register records what the entity declared. It does not record whether the declaration is accurate.
Source: CRBR — Centralny Rejestr Beneficjentów Rzeczywistych · extracted 2026-09-15
What the extract contains
A CRBR extract for a single entity returns the following data fields:
| Field | Content |
|---|---|
| Entity name | Legal name as registered in KRS |
| KRS number | National Court Register identifier |
| NIP | Tax identification number |
| Beneficial owner — name | First and last name |
| Beneficial owner — nationality | As declared |
| Beneficial owner — country of residence | As declared |
| Beneficial owner — date of birth | As declared |
| Beneficial owner — PESEL | Polish national ID number, where applicable |
| Nature of control | Category: shares, voting rights, other means, senior management |
| Extent of control | Percentage range or qualitative description |
| Date of entry | Date the declaration was submitted |
| Date of last update | Date of most recent amendment |
The extract is generated in real time from the live database. It reflects the state of the register at the moment of retrieval. It does not reflect the state of the register at any prior date: the CRBR does not provide historical snapshots through its public interface.
Source: CRBR — Centralny Rejestr Beneficjentów Rzeczywistych · extracted 2026-09-15
The control layer: what the register establishes and what it does not
The CRBR establishes the declared control position. It does not establish the actual control position. The distinction is material for a cross-border buyer.
The register shows the name of the person the entity identified as its beneficial owner. It does not show the ownership chain that led to that identification. It does not show whether intermediate holding companies are Polish or foreign. It does not show whether the declared percentage reflects direct shareholding, indirect shareholding, or a combination.
To reconstruct the chain, a separate extract from the National Court Register (KRS) is required. The KRS records the direct shareholders of a Polish limited liability company (spółka z ograniczoną odpowiedzialnością) in the Gesellschafterliste equivalent — the lista wspólników. For a joint-stock company (spółka akcyjna), bearer shares and nominee arrangements may interrupt the chain at the KRS level.
Where the declared beneficial owner is a foreign national or a foreign entity appears in the chain, the CRBR entry does not cross-reference any foreign register. The chain stops at the Polish border in terms of what the CRBR itself provides.
Source: CRBR — Centralny Rejestr Beneficjentów Rzeczywistych; KRS — Krajowy Rejestr Sądowy · extracted 2026-09-15
Timeline and access mechanics
The CRBR is available through the Ministry of Finance portal at crbr.podatki.gov.pl. Search is by entity name or NIP. The extract is generated immediately upon query. There is no processing delay at the register level.
For a foreign requester, the practical path involves: identifying the correct NIP or KRS number for the target entity, navigating the Polish-language interface, interpreting the output fields, and cross-referencing the result against the KRS and, where relevant, the insolvency register (Rejestr Dłużników Niewypłacalnych, RDN, and the restructuring and bankruptcy register, KRZ).
The register does not issue a certified paper extract through its public interface. Official certified extracts for use in foreign proceedings require a separate application through a notary or through the Ministry of Finance's formal certification channel.
Source: CRBR — crbr.podatki.gov.pl · extracted 2026-09-15
The limit of what the sources allow
The CRBR records a declaration. It does not verify it. The following limits apply regardless of how the query is structured.
The register does not show the intermediate ownership chain. A declared beneficial owner holding control "through other means" may exercise that control through a shareholders' agreement, a pledge over shares, or a management agreement. None of those instruments appear in the CRBR.
The register does not provide historical data through its public interface. If the beneficial owner changed six months ago, the current extract shows the current entry only. The prior entry is not accessible through the standard public query.
The register does not cover all Polish legal entities. Certain entity types — including civil law partnerships (spółki cywilne) and sole traders — fall outside the reporting obligation. A CRBR result of "no entry found" for such an entity is not evidence of non-existence.
The register does not cross-reference foreign registers. Where the chain passes through a foreign holding company, the CRBR entry identifies the natural person at the top of the chain as declared by the Polish entity. It does not confirm that the foreign intermediate entity exists, is in good standing, or holds the stake attributed to it.
The ceiling of what the sources allow is stated before payment.
Source: CRBR — Centralny Rejestr Beneficjentów Rzeczywistych · extracted 2026-09-15
Where the sources disagree
A CRBR entry and a KRS lista wspólników may show different persons in a control position. This is not necessarily an error. The KRS records direct shareholders; the CRBR records the natural person at the end of the chain. Where a Polish company is wholly owned by a foreign holding company, the KRS shows the foreign holding company as the sole shareholder. The CRBR shows the natural person who controls that foreign holding company.
Where the two registers show inconsistent data — for example, where the KRS records a direct individual shareholder above 25 percent who does not appear in the CRBR — the discrepancy is itself a finding. It may reflect a reporting failure, a recent change not yet updated in one register, or a structural arrangement that the entity has not disclosed.
A discrepancy between the CRBR entry and the entity's own articles of association or shareholders' agreement is a separate category of finding. Those documents are not part of the CRBR. They are retrievable from the KRS document repository.
Source: CRBR; KRS — Krajowy Rejestr Sądowy · extracted 2026-09-15
Scope and fixed price
| Tier | Price | What is included | Not included |
|---|---|---|---|
| Signal | €440 | CRBR extract for one entity; KRS identification; English-language summary of declared control position; date of last update noted | KRS document retrieval; intermediate chain reconstruction; insolvency register check; historical entries |
| Standard | €890 | All Signal items; KRS extract with direct shareholder data; lista wspólników review; cross-reference of CRBR and KRS entries; discrepancy note where applicable; insolvency register (KRZ/RDN) check | Foreign register queries; certified extract for court use; legal opinion on control structure |
| Extended | €1,800 | All Standard items; intermediate chain reconstruction to the extent Polish registers permit; review of KRS document repository (articles of association, shareholder resolutions); identification of chain interruption points; written analysis of where the chain stops and why | Foreign register queries beyond Polish jurisdiction; legal qualification of findings; certified extracts; representation |
FAQ
Is the CRBR the same as a UBO register under EU AML directives? The CRBR was established to implement the EU's Fourth Anti-Money Laundering Directive and subsequently amended to reflect the Fifth. It is Poland's national beneficial ownership register within that framework. Following the CJEU judgment in joined cases C-37/20 and C-601/20 (WM and Sovim, November 2022), several EU member states restricted public access to their UBO registers. Poland's CRBR has remained publicly accessible. The current access regime should be verified against the register's operational status at the time of any query.
What happens if the entity has no CRBR entry? An absence of entry may mean the entity is not subject to the reporting obligation, has not yet complied, or has been dissolved. The absence of a CRBR entry does not confirm any of these. A KRS check is required to determine the entity's current status and whether the reporting obligation applies.
Can the CRBR extract be used in foreign proceedings? The standard extract generated through the public interface is not certified. For use in foreign legal proceedings, a certified extract issued through official channels is required. The process and cost for certification are set by the issuing authority and are not fixed in advance.
Does the CRBR show historical beneficial owners? The public interface returns the current entry only. Historical entries are not accessible through the standard public query. Requests for historical data require a formal application to the competent authority; the conditions and timeline for such requests are governed by Polish administrative procedure.
What if the declared beneficial owner is a foreign national? The CRBR records nationality and country of residence as declared. It does not cross-reference any foreign identity register or foreign beneficial ownership register. Verification of a foreign national's identity or of a foreign entity's ownership structure requires separate queries in the relevant foreign jurisdiction.
Sources:
- CRBR — Centralny Rejestr Beneficjentów Rzeczywistych — https://crbr.podatki.gov.pl — extracted 2026-09-15
- KRS — Krajowy Rejestr Sądowy — https://ekrs.ms.gov.pl — extracted 2026-09-15
- KRZ — Krajowy Rejestr Zadłużonych — https://krz.ms.gov.pl — extracted 2026-09-15
- AML Act — Ustawa z dnia 1 marca 2018 r. o przeciwdziałaniu praniu pieniędzy oraz finansowaniu terroryzmu — verified 2026-09-15
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Disclaimer: This report is a factual compilation from official registers and public sources. It is provided for informational purposes only, does not constitute legal advice, and contains no legal qualification of the facts established. VLO Law Firm assumes no liability for actions taken or not taken based on this material. For advice regarding your particular situation, please contact info@vlolawfirm.com.
Author: Katharina Berg — Partner, Central Europe, VLO Law Firm
