New regulations concerning registration of ultimate beneficial owners (UBO) have been recently implemented in Poland. A new law covers the following entities: partnerships (Polish sp.j), limited partnership, partnership limited by shares and limited liability company. These regulations are based on an EU directive which had to be implemented to the Polish legal system. The legal basis of creation of the register of UBO’s is the 12th April 2018 legislation; aimed at preventing money laundering/financing terrorism.

The new rules are applied for new entities from 13th October 2019. The UBO which has been operating before, will be obliged to register after April 2020.

UBO registration concerns the natural person(s) whose participation in the company exceed 25% and those who ultimately own or control customers and/or the natural person on whose behalf a transaction is being conducted. The registration also includes those persons who exercise ultimate effective control over a legal person or organisation. The registration is on the Ministry of Finance website. The maximum penalty for non-compliance can be up to 1 million PLN.