Central Registry of Ultimate Beneficiaries (CRBR)
By 13 July 2020, commercial companies are required to submit a notification to the Central Registry of Ultimate Beneficiaries (CRBR).
Who is it for?
Commercial companies: general partnership, limited partnership, limited joint-stock partnership, limited liability and joint stock partnership (without public companies).
What is the purpose of CRBR?
The purpose of disclosure in the registry is to prevent money laundering and terrorist financing by making it impossible to conceal one’s identity in a complex corporate structure. The registry is publicly available at https://crbr.podatki.gov.pl/.
What data needs to be disclosed?
– company’s basic identification data,
– data of company’s ultimate beneficiaries, i.e. natural persons exercising direct or indirect control over the company.
Who can apply?
The application to the CRBR must be made by persons authorised to represent the entity on their own, using a qualified electronic signature or a trusted ePUAP profile (PESEL required). Disclosure of untrue information, in particular the lack of proper identification of the actual beneficiary, may result in criminal or financial liability.
The Law Firm provides:
- analysis of the company’s corporate structure and identification of actual beneficiaries;
- preparation of the application form for CRBR in xml format;
- detailed instructions for filing the application electronically and ongoing support in the process;
- support in the process of obtaining a PESEL number;
- help in establishing a trusted ePUAP profile used for communication with authorities in Poland;
- support in obtaining a qualified electronic signature, which replaces the wet ink signature.
An additional benefit related to the analysis of the company’s corporate structure is the identification of personal and corporate ties, which are important i.e. in determining the status of SMEs when applying for public funding and in the course of the company’s day-to-day operations (e.g. for the purposes of contact with banks, capital market institutions, carrying out certain notarial activities, etc.). The electronic signature / ePUAP can be later used in daily business of the company, including submission of yearly financial statements to the court.
Newly established companies are obliged to report to the CRBR within 7 days from their entry into the KRS. The same deadline applies in case of change of beneficiaries’ data.