Ownership map
Trace each ownership and control layer until the relevant natural persons are identified.
CRBR · INTERNATIONAL COMPANY
CRBR for a Polish limited company with a foreign shareholder
A foreign shareholder does not remove the Polish company's beneficial-owner reporting obligations. The company should identify the natural person or persons exercising ultimate control, collect the required data and update the register when the ownership or control structure changes.
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Information checked on 29 August 2026. The Polish Ministry of Finance explains that beneficial ownership requires analysis of direct and indirect control. A person without a PESEL number provides their date of birth. Source: Ministry of Finance — CRBR guidance ↗.
MORE THAN A SHARE PERCENTAGE
The beneficial owner is the natural person who ultimately controls the entity
In a simple ownership structure the answer may be straightforward, but indirect ownership, voting rights, shareholder agreements or other control rights can change the analysis.
The Ministry of Finance notes that holding 25% or less does not make a person a beneficial owner on that fact alone, but the person may still meet other control criteria. International ownership chains should therefore be traced through to the relevant natural person or persons.
PREPARING THE FILING
Four steps for an international ownership structure
Personal data
For a person without PESEL, official CRBR guidance provides for the date of birth to be entered.
Authorised filer
The filing is made by a person legally authorised to represent the reporting entity or another person permitted by the applicable rules.
Updates
When reportable data changes, determine the event date and current statutory deadline rather than relying on an old checklist.
DEADLINES
Use current official guidance for the applicable filing deadline
CRBR rules and deadlines have changed over time. For each new filing or update, check the current legal rules and official instructions for the entity concerned.
Initial filing
The deadline runs from the relevant event defined by the current rules for the entity.
Changes
A change in beneficial ownership, control or reportable data can trigger a separate update obligation.
Event date
The CRBR filing uses the date of the event that caused the reporting obligation, not simply the filing date.
Evidence
For cross-border structures, keep the documents used to determine ultimate control.
CONTACT
Does your Polish company have a foreign or multi-level ownership structure?
We can help organise the ownership data used in ongoing company support and identify issues that require separate legal or corporate verification.