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Poland: Register of ultimate beneficial owners; reporting deadline 13 April 2020

Poland: Register of ultimate beneficial owners

Existing companies must report certain information to a central register with regard to their ultimate beneficial owners by 13 April 2020 (a date that is six months following the 13 October 2019 date of implementation).


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Newly established companies must notify the register of their ultimate beneficial owners within seven days from the date when the company is added to the national court register. A seven-day notification deadline also applies in the event of a change in the information previously provided to the register of ultimate beneficial owners.

For these purposes, the term “beneficial owner” is aligned with anti-money laundering and terrorist financing legislation. A beneficial owner is a natural person or group of individuals exercising direct or indirect control over a entity (company). To determine the beneficial owner of a company, it is necessary to consider first whether they are natural persons who possess at least 25% of the shares/voting rights in the company (whether directly or indirectly through other companies). If the structure of the capital group includes entities other than companies (such as investment funds), determining who is the beneficial owner will require more detailed analysis.

Entities required to disclose beneficial owners

Entities required to disclose (and update) information about their beneficial owners include:

  • General partnerships
  • Limited partnerships
  • Limited joint-stock partnerships
  • Limited liability companies
  • Joint-stock companies (excluding public companies)

Persons assigned notification responsibility

represent the company or entity in accordance with the entity’s general rules of representation. The notification is to be submitted in the form of an electronic document and must include an attestation statement signed by the person making the report (that is a statement attesting to the fact that the data contained therein is true).

Read an August 2019 report [PDF 199 KB] prepared by the KPMG member firm in Poland

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