The Central Register of Beneficial Owners (CRBR) in Poland has so far functioned as a publicly accessible database providing information about company owners and key decision-makers. However, a draft amendment to the Act on Counteracting Money Laundering and Terrorist Financing (the AML Act), prepared by the Polish Ministry of Finance, intends to change this. The proposed regulations respond to EU directives and a 2022 ruling by the Court of Justice of the European Union, which emphasized the need to better protect the privacy rights of individuals identified as beneficial owners.
What would reduced transparency mean for the CRBR in Poland?
According to the draft, the CRBR, currently available online to anyone interested, would face significant restrictions in access. Unrestricted data access would be reserved only for public authorities, such as law enforcement agencies, intelligence services, and the National Tax Administration. Other parties wishing to obtain beneficial owner data would be required to submit an application demonstrating a legitimate interest.
Who would be able to request access to CRBR information?
The draft legislation stipulates that only entities proving a legitimate interest related to preventing money laundering, terrorist financing, or conducting a business transaction with an entity registered in the CRBR would be able to request access.
This group would include:
- Investigative journalists examining financial flows and ownership,
- NGOs combating financial crimes,
- Academic researchers focusing on legal or financial issues,
- Individuals or companies planning to enter into contracts or business relationships with CRBR-registered entities.
Applications would be submitted electronically, with processing expected within 12 working days; however, delays of up to an additional 24 days could occur during busy periods.
What constitutes a “legitimate interest”?
While the draft does not provide a precise definition of legitimate interest, it would generally be assessed based on two main factors:
- The identity and role of the applicant requesting the information,
- The nature of the connection between the applicant and the data subject, such as a potential business transaction.
Certain groups, including media representatives, NGOs, and academics engaged in anti-money laundering or counter-terrorism research, would likely be presumed to have a legitimate interest automatically.
Implications for businesses and professionals
For lawyers, compliance officers, and advisors who regularly analyze company ownership structures, the proposed changes would mean adapting to a more formal and time-consuming process for accessing CRBR data. The restrictions could also reduce market transparency, as entrepreneurs seeking to verify contractors or ownership links might face additional barriers.
When will these changes take effect?
Although the draft scheduled the full restrictions on CRBR transparency to take effect on July 1, 2026, these changes have not yet come into force in practice.
The proposed amendment to the AML Act would fundamentally alter access to the Central Register of Beneficial Owners. The register would no longer be fully open to the public; instead, access would depend on demonstrating a legitimate interest. While the aim is to strengthen personal data protection, these changes could also impact market transparency and efforts to combat money laundering. The final outcome will depend on the law’s adoption and practical implementation, as well as balancing privacy with transparency in business.
