{"id":3849,"date":"2026-07-30T11:33:23","date_gmt":"2026-07-30T11:33:23","guid":{"rendered":"https:\/\/sawaryn.com\/?p=3849"},"modified":"2026-10-26T11:06:00","modified_gmt":"2026-10-26T11:06:00","slug":"poland-family-foundations-register-tax-rules-2026","status":"publish","type":"post","link":"https:\/\/sawaryn.com\/en\/publikacje\/poland-family-foundations-register-tax-rules-2026\/","title":{"rendered":"Family Foundations in 2026. Online Register and Taxes: What Founders Need to Know"},"content":{"rendered":"

More than 3,600 family foundations entered in the register, another 3,200 waiting in line, and only one registry court – in Piotrk\u00f3w Trybunalski. If you run a family foundation<\/a> or are planning to establish one, two events in 2026 directly affect your decisions.<\/p>\n

First: from 29 July 2026<\/strong>, family foundation data will be available online for the first time, and applications for copies of register entries can be submitted electronically. Second: the presidential veto<\/strong> of the CIT amendment in late November 2025 means that family foundations will operate in 2026 under the existing tax rules – without a lock-up, exit tax or restrictions on rental activities.<\/p>\n

This window may not remain open forever. The Ministry of Finance may return with another version of the bill tightening the CIT rules. It is therefore worth knowing exactly what has changed, what still cannot be expedited and how to prepare your foundation\u2019s structure for the possible return of these regulations.<\/p>\n

In this article, you will find: the scope of the register\u2019s digitisation, realistic waiting times for documents, the tax rules applicable after the veto and specific actions worth taking as a founder or member of a foundation\u2019s management board.<\/p>\n

Key terms you need to know<\/h2>\n

Before we move on to the details, here are several terms that appear later in the article:<\/p>\n\n\n\n\n\n\n\n\n\n\n\n
Term<\/th>\nMeaning<\/th>\n<\/tr>\n<\/thead>\n
Register of Family Foundations (RFR)<\/strong><\/td>\nA separate register maintained exclusively by the Regional Court in Piotrk\u00f3w Trybunalski – it is not part of the National Court Register (KRS)<\/td>\n<\/tr>\n
Current copy<\/strong><\/td>\nA document containing the current entries under a given RFR number<\/td>\n<\/tr>\n
Full copy<\/strong><\/td>\nA document containing all entries from the initial registration onwards<\/td>\n<\/tr>\n
Lock-up<\/strong><\/td>\nA mechanism included in the vetoed bill – a ban on disposing of assets contributed to the foundation before the end of a 36-month period, subject to the loss of the CIT exemption<\/td>\n<\/tr>\n
Hidden profits<\/strong><\/td>\nBenefits provided by the foundation to a beneficiary, founder or related entities that are subject to 15% CIT<\/td>\n<\/tr>\n
Zero tax group<\/strong><\/td>\nThe founder\u2019s closest family (spouse, descendants, ascendants, stepchildren, siblings, stepfather, stepmother) – exempt from PIT on benefits received from the foundation<\/td>\n<\/tr>\n
Exit tax<\/strong><\/td>\nA tax on unrealised gains – under the vetoed bill, it would have applied to family foundations<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

What changes with the digitisation of the Register of Family Foundations from 29 July 2026?<\/h2>\n

The Regulation of the Minister of Justice of 22 April 2026 (Journal of Laws 2026, item 577) introduces two changes: public online access to basic foundation data and the option to submit electronic applications for documents from the register.<\/p>\n

Data available without an application<\/h3>\n

From 29 July 2026, five categories of data can be checked on the website of the Regional Court in Piotrk\u00f3w Trybunalski:<\/p>\n\n\n\n\n\n\n\n\n\n
Data available online<\/th>\nData unavailable online<\/th>\n<\/tr>\n<\/thead>\n
RFR number<\/td>\nAmount of the founding fund<\/td>\n<\/tr>\n
Name of the family foundation<\/td>\nDetails of founders and beneficiaries<\/td>\n<\/tr>\n
Foundation\u2019s registered office<\/td>\nComposition of the foundation\u2019s governing bodies<\/td>\n<\/tr>\n
NIP number (if entered)<\/td>\nRules of representation<\/td>\n<\/tr>\n
REGON number (if entered)<\/td>\nEntry history<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

The data is updated automatically at least once a day<\/strong>, after the court\u2019s office hours. It is made available as a computer printout. The regulations do not specify the file format (PDF, HTML or another format), nor do they provide for an API or bulk data downloads.<\/p>\n

The publicly available data does not include personal data<\/strong> concerning founders, beneficiaries or members of the foundation\u2019s governing bodies – which is consistent with GDPR requirements.<\/p>\n

Electronic applications for copies and certificates<\/h3>\n

If you need more than the basic data, from 29 July 2026 you can submit an application for a copy, extract, certificate or information from the register electronically<\/strong>:<\/p>\n

    \n
  1. Prepare an application specifying the type of document and the RFR number<\/li>\n
  2. Sign it with a qualified electronic signature or a trusted signature<\/li>\n
  3. Attach proof of payment of the administrative fee – PLN 20<\/strong><\/li>\n
  4. Send it to the registry court\u2019s email address provided on the court\u2019s website<\/li>\n
  5. You will receive the document at your email address, bearing the qualified electronic signature of a court employee or the court\u2019s qualified electronic seal<\/li>\n<\/ol>\n

    Electronic documents have the same legal effect as their paper counterparts.<\/p>\n

    What digitisation does not resolve<\/h3>\n

    Digitisation applies only to the form of communication. The regulation does not introduce any deadline for processing<\/strong> an application submitted electronically. According to industry estimates, the waiting time for a copy from the Register of Family Foundations is approximately 4-6 weeks<\/strong>. There are no official statistics from the court or the Ministry of Justice confirming this timeframe.<\/p>\n

    By comparison, in the National Court Register (KRS), a current copy is available immediately when an application is submitted in person, or within 30 days when it is sent by post. Data equivalent to copies of register entries can be downloaded free of charge and immediately through the Court Registers Portal (prs.ms.gov.pl). No equivalent solution exists for the Register of Family Foundations.<\/p>\n\n\n\n\n\n\n\n\n\n
    Parameter<\/th>\nRegister of Family Foundations<\/th>\nNational Court Register (KRS)<\/th>\n<\/tr>\n<\/thead>\n
    Basic data online<\/td>\nFrom 29.07.2026-5 categories<\/td>\nFull copies available free of charge at prs.ms.gov.pl<\/td>\n<\/tr>\n
    Fee for a copy<\/td>\nPLN 20<\/td>\nPLN 30 (current) \/ PLN 60 (full)<\/td>\n<\/tr>\n
    Waiting time for a copy<\/td>\nEstimated at 4-6 weeks<\/td>\nImmediately (online) to 30 days (by post)<\/td>\n<\/tr>\n
    Electronic application<\/td>\nFrom 29.07.2026 (email + signature)<\/td>\nThrough the prs.ms.gov.pl portal<\/td>\n<\/tr>\n
    Number of courts maintaining the register<\/td>\n1 (Piotrk\u00f3w Trybunalski)<\/td>\nSeveral dozen registry courts<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

    The Ministry of Justice is conducting \u201cadvanced conceptual work” on incorporating the Register of Family Foundations into the National Court Register, but it has not published a timetable<\/strong> with dates or milestones. The April 2026 regulation is being treated as the \u201cfirst step” towards eventual integration.<\/p>\n

    Contact us<\/a><\/p>\n

    Tax rules for family foundations in 2026 – the position following the presidential veto<\/h2>\n

    In late November 2025, the President of the Republic of Poland vetoed an amendment to the CIT Act<\/a> (Sejm paper no. 1753), which was due to enter into force on 1 January 2026. In his grounds for the veto, he pointed to the need to reduce the risk of tax optimisation using family foundations, but emphasised the principle of trust in the state and the stability of the law.<\/p>\n

    As a result, family foundations will operate in 2026 under the existing rules:<\/p>\n\n\n\n\n\n\n\n\n\n\n
    Event<\/th>\nApplicable rate in 2026<\/th>\n<\/tr>\n<\/thead>\n
    Income from permitted activities (dividends, capital gains, rent, interest)<\/td>\nEntity-based CIT exemption<\/strong><\/td>\n<\/tr>\n
    Reinvestment of profits within the foundation<\/td>\nNo tax<\/strong><\/td>\n<\/tr>\n
    Payment of a benefit to a beneficiary<\/td>\n15% CIT<\/strong> payable by the foundation<\/td>\n<\/tr>\n
    Receipt of a benefit by a beneficiary from the \u201czero tax group”<\/td>\n0% PIT<\/strong> (exemption)<\/td>\n<\/tr>\n
    Receipt of a benefit by other beneficiaries<\/td>\n15% PIT<\/strong><\/td>\n<\/tr>\n
    Disposal of assets contributed to the foundation<\/td>\nNo time restrictions<\/strong> (no lock-up)<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

    The minimum value of the founding fund is PLN 100,000<\/strong>.<\/p>\n

    What the vetoed bill contained and why you should know about it<\/h3>\n

    The vetoed bill (paper no. 1753) provided for changes that may return in a subsequent version of the legislation. Understanding their scope makes it possible to prepare the foundation\u2019s structure for different scenarios:<\/p>\n\n\n\n\n\n\n\n\n\n\n\n\n
    Proposed change<\/th>\nEffect on the foundation<\/th>\n<\/tr>\n<\/thead>\n
    Three-year lock-up<\/strong><\/td>\nSale of property contributed by related entities before the end of 36 months – loss of the CIT exemption<\/td>\n<\/tr>\n
    Exit tax<\/strong><\/td>\nTaxation of the foundation\u2019s unrealised gains<\/td>\n<\/tr>\n
    Application of CFC rules<\/strong><\/td>\nThe foundation would lose its CIT exemption in respect of income from controlled foreign companies<\/td>\n<\/tr>\n
    Exclusion of short-term rentals<\/strong><\/td>\nCIT exemption only for long-term residential rentals for individuals\u2019 own needs<\/td>\n<\/tr>\n
    Exclusion of hotel activities<\/strong><\/td>\nRemoval from the list of activities permitted for foundations<\/td>\n<\/tr>\n
    Expansion of hidden profits<\/strong><\/td>\nIncluding loans to beneficiaries not repaid on time, loans granted for 10+ years, donations and transactions with related entities at non-market prices<\/td>\n<\/tr>\n
    Change in PIT rates<\/strong><\/td>\n10% PIT for beneficiaries in tax groups I\/II (instead of the current exemption for the \u201czero tax group”), 15% PIT for others<\/td>\n<\/tr>\n
    Exclusion from the preferential 9% CIT rate<\/strong><\/td>\nA family foundation would not be eligible for the 9% CIT rate<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

    Transitional lock-up provisions – what was planned<\/h3>\n

    The bill provided for a cut-off date of 31 August 2025<\/strong> as the reference point:<\/p>\n

      \n
    1. Assets contributed before 31 August 2025<\/strong> – outside the scope of the lock-up, allowing the foundation to dispose of them without restrictions<\/li>\n
    2. Assets contributed after 31 August 2025 but before 1 January 2026<\/strong> – subject to the lock-up, even though the legislation was not yet formally in force<\/li>\n
    3. Assets contributed from 1 January 2026<\/strong> – subject to the lock-up under the standard rules<\/li>\n<\/ol>\n

      The date of 31 August 2025 was linked to the publication date of the bill (around 29 August 2025). Commentators pointed to the \u201cquasi-retroactive” nature of these provisions – the new regulations would affect the tax consequences of future events by taking into account actions performed before they entered into force. Potential incompatibility with Article 2 of the Constitution of the Republic of Poland (the principle of protecting citizens\u2019 trust in the state and the law) was also raised.<\/p>\n

      The lock-up does not apply<\/strong> – the presidential veto prevented these provisions from entering into force. A family foundation may currently dispose of contributed assets while retaining its CIT exemption, without any time restrictions.<\/p>\n

      Is the Ministry of Finance working on a new bill?<\/h3>\n

      The Ministry of Finance\u2019s list of legislative work (updated on 25 May 2026 and covering the period until 31 December 2026) does not contain an entry<\/strong> concerning a new bill amending CIT rules for family foundations. There are no new Sejm papers and no ministry announcements that work has begun.<\/p>\n

      This does not mean that the matter is closed. Article 143 of the Family Foundation Act requires the Council of Ministers to review how the legislation operates after 3 years from the Act\u2019s entry into force (i.e. after 22 May 2026). Preliminary consultations conducted by the Ministry of Development and Technology ran from December 2025 to May 2026. The review\u2019s findings may form the basis for a new legislative initiative.<\/p>\n

      What to do now – recommendations for founders and management boards<\/h2>\n

      Register-related measures<\/h3>\n
        \n
      1. Test the new electronic channel.<\/strong> Email an application for a copy from the Register of Family Foundations using a trusted profile and measure the processing time. This will tell you how long the procedure actually takes in your case – industry estimates indicate 4-6 weeks, but there is no official data<\/li>\n
      2. Update your internal due diligence procedures.<\/strong> Add the new data source to your transaction checklist: the website of the Regional Court in Piotrk\u00f3w Trybunalski (basic data available without an application). In transactions involving a family foundation, a counterparty can verify the RFR number, name, registered office, NIP and REGON within minutes<\/li>\n
      3. Inform counterparties, banks and notaries<\/strong> about the option to verify the foundation\u2019s data electronically and order copies online. This will shorten the due diligence process for transactions in which the foundation is a shareholder in a company or owns real estate<\/li>\n
      4. If you are planning to register a new family foundation<\/strong> – submit your application as soon as possible. With more than 3,200 applications in the queue, the waiting time for registration is over a year. Plan an interim structure (e.g. establishing special-purpose vehicles<\/a>, agreements with beneficiaries) for the waiting period<\/li>\n<\/ol>\n

        Tax-related measures<\/h3>\n
          \n
        1. Ask a lawyer to review the foundation\u2019s structure<\/strong> for resilience against the potential return of the CIT amendment. Check how the lock-up, exit tax and expanded definition of hidden profits would affect your assets and transactions – and prepare a contingency plan<\/li>\n
        2. Identify foundation assets that could be subject to the lock-up<\/strong> if the bill returns. Prepare documentation substantiating the current structure – contribution dates, market values and links to related entities (5% ownership threshold)<\/li>\n
        3. Analyse intra-foundation loans.<\/strong> If the foundation has granted loans to beneficiaries, check their repayment dates and the periods for which they were granted. The proposed rules classified loans not repaid on time or granted for 10+ years as taxable hidden profits<\/li>\n
        4. Review the rental structure.<\/strong> If the foundation rents property to related entities or engages in short-term rentals, assess how excluding this income from the CIT exemption would affect the foundation\u2019s financial model<\/li>\n
        5. Monitor legislative work.<\/strong> Appoint a person responsible for monitoring the Ministry of Finance\u2019s list of legislative work, the findings of the review of the Family Foundation Act (Article 143) and the Ministry of Justice\u2019s work on incorporating the RFR into the National Court Register<\/li>\n<\/ol>\n

          How we can help<\/h2>\n

          Digitising the register is a step forward, but it does not change the fact that a family foundation requires a well-organised legal structure – particularly at a time when the tax rules may change.<\/p>\n

          We support founders and management boards of family foundations in three areas:<\/p>\n

            \n
          1. Reviewing the foundation\u2019s structure for tax risks.<\/strong> We analyse assets, intra-foundation transactions, loans and rental agreements – and identify which elements need to be adjusted in case the CIT amendment returns<\/li>\n
          2. Preparing transaction documentation.<\/strong> If the foundation is a shareholder in a company, owns real estate or is a party to agreements with related entities, we organise the documents, dates and values so that your position is consistent and properly documented<\/li>\n
          3. Ongoing legal support and legislative monitoring.<\/strong> We monitor work on CIT amendments, the review of the Family Foundation Act and the integration of the RFR with the National Court Register – and inform you of changes that require action<\/li>\n<\/ol>\n

            If you run a family foundation or are planning to establish one – contact us<\/a>. We will help you take advantage of the current tax window and prepare your structure for different regulatory scenarios.<\/p>\n

            Family foundations in 2026 – take advantage of the current window before it closes<\/h2>\n

            Two events define the position of family foundations in 2026: the partial digitisation of the register from 29 July and the continuation of the existing tax rules following the presidential veto. Digitisation makes it easier to verify data and order documents, but it does not eliminate the weeks-long wait for copies or the months-long registration queues. The veto gives foundations time – reinvestment without CIT, no lock-up and a PIT exemption for the \u201czero tax group” – but the Ministry of Finance may return with a new bill once the review of the legislation has been completed.<\/p>\n

            That is why now is a good time to review the foundation\u2019s structure, organise its documentation and prepare alternative tax scenarios. Do not wait for another bill – contact us<\/a> and find out whether your foundation is ready for change.<\/p>\n

            Frequently asked questions<\/h2>\n

            From 29 July 2026, can I check online who the founder or beneficiary of a particular family foundation is?<\/strong>
            \nNo. The data made available on the court\u2019s website includes only the RFR number, name, registered office, NIP and REGON. The personal data of founders, beneficiaries and members of governing bodies is not made public – in accordance with GDPR requirements. To obtain a broader range of information, you must apply for a copy from the register.<\/p>\n

            How long will I actually wait for an electronic copy from the Register of Family Foundations?<\/strong>
            \nThe regulation does not specify any deadline for processing an application. Industry estimates indicate approximately 4-6 weeks, but there are no official court statistics. Digitisation speeds up the submission of the application and receipt of the document (email instead of post), but the time needed for the court to prepare the copy remains unchanged – applications are still processed manually by court employees.<\/p>\n

            Does an electronic copy from the Register of Family Foundations have the same legal effect as a paper copy?<\/strong>
            \nYes. Electronic documents prepared by the court bear the qualified electronic signature of an authorised employee or the court\u2019s qualified electronic seal – they have the same legal effect as copies issued on paper.<\/p>\n

            Should I expedite transactions involving the foundation before the bill tightening the CIT rules returns?<\/strong>
            \nThis depends on the type of transaction and the assets involved. The current rules allow foundation assets to be disposed of while retaining the CIT exemption, without any time restrictions. If you are planning transactions that could be subject to the lock-up (disposal of property contributed by related entities) or exit tax, it is worth reviewing the timeline with a lawyer. The Ministry of Finance has not formally initiated a new bill, but the statutory review (Article 143) may prompt another legislative initiative.<\/p>\n

            When will the Register of Family Foundations be incorporated into the National Court Register?<\/strong>
            \nThere is no specific date. The Ministry of Justice is conducting \u201cadvanced conceptual work” in cooperation with the Ministry of Development and Technology, but it has not published a timetable. The April 2026 regulation is being treated as the \u201cfirst step” – ultimately, the RFR is to be integrated with the National Court Register and the Court Registers Portal, which would provide free and immediate access to full data, as is currently the case with the National Court Register.<\/p>\n

            How should I plan succession when registration of a foundation takes over a year?<\/strong>
            \nSubmit your registration application as soon as possible – with more than 3,200 applications in the queue, the waiting time is long. Plan an interim structure for the waiting period: establishing special-purpose vehicles, preparing agreements with beneficiaries and organising asset documentation. A family foundation in formation may conduct business, but remember the 6-month deadline for submitting the registration application – under the vetoed bill, missing this deadline would have resulted in the retroactive loss of the CIT exemption from the date on which the foundation was established.<\/p>\n","protected":false},"excerpt":{"rendered":"

            In 2026, family foundations face register digitalisation from 29 July and no CIT changes after the veto. Review risks, timelines and next steps.<\/p>\n","protected":false},"author":9,"featured_media":2567,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"footnotes":"","sip_alt_url":"","sip_en_pl_url":"","sip_pair_uuid":"","sip_pair_state":""},"categories":[1579],"tags":[1548,1628,1446,1531,1549],"specialization":[1213],"practice_area":[],"class_list":["post-3849","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-corporate-law","tag-due-diligence-en","tag-fundacja-rodzinna","tag-gdpr","tag-personal-data-protection","tag-taxes-en","specialization-corporate-law"],"acf":[],"_links":{"self":[{"href":"https:\/\/sawaryn.com\/en\/wp-json\/wp\/v2\/posts\/3849","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/sawaryn.com\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/sawaryn.com\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/sawaryn.com\/en\/wp-json\/wp\/v2\/users\/9"}],"replies":[{"embeddable":true,"href":"https:\/\/sawaryn.com\/en\/wp-json\/wp\/v2\/comments?post=3849"}],"version-history":[{"count":1,"href":"https:\/\/sawaryn.com\/en\/wp-json\/wp\/v2\/posts\/3849\/revisions"}],"predecessor-version":[{"id":4234,"href":"https:\/\/sawaryn.com\/en\/wp-json\/wp\/v2\/posts\/3849\/revisions\/4234"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/sawaryn.com\/en\/wp-json\/wp\/v2\/media\/2567"}],"wp:attachment":[{"href":"https:\/\/sawaryn.com\/en\/wp-json\/wp\/v2\/media?parent=3849"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/sawaryn.com\/en\/wp-json\/wp\/v2\/categories?post=3849"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/sawaryn.com\/en\/wp-json\/wp\/v2\/tags?post=3849"},{"taxonomy":"specialization","embeddable":true,"href":"https:\/\/sawaryn.com\/en\/wp-json\/wp\/v2\/specialization?post=3849"},{"taxonomy":"practice_area","embeddable":true,"href":"https:\/\/sawaryn.com\/en\/wp-json\/wp\/v2\/practice_area?post=3849"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}