CRBR data used to be fully public. Following an amendment, only specified entities may access the register directly, and only if additional conditions are met. This follows a 2022 judgment of the Court of Justice of the European Union, which found unrestricted access to be a disproportionate interference with the right to privacy.<\/p>\n
Businesses, journalists and social organizations no longer have unrestricted access. To obtain data, you must:<\/p>\n
In practice, information that previously took minutes to check now requires a formal application and a wait. Adjust your onboarding, counterparty-audit and AML risk-assessment<\/a><\/strong> procedures to the new timelines.<\/p>\n If you are not an obliged entity, you must follow the application process. The steps are:<\/p>\n 10 July 2025<\/strong>: the rules for the new access procedure entered into force.<\/p>\n July 2026<\/strong>: a second reform phase is planned. It would narrow the scope of data disclosed and allow access to be excluded in cases of abuse or a threat to a beneficial owner’s security.<\/p>\n Reporting a beneficial owner<\/a><\/strong> is not a one-off formality. The amendment strengthened the duty to keep data updated. If you operate a company, you must:<\/p>\n Failure to update data, or submitting incomplete or false information, violates the AML Act and may have the consequences described below.<\/p>\n The amendment tightened the penalties. The legislature treats CRBR duties as ongoing, and failure to meet them may have serious consequences.<\/p>\n Liability does not stop at company level. A person who submits information to the register may face:<\/p>\n Managing CRBR therefore requires both knowledge of the rules and organizational care. Appoint a person responsible and establish a verification process before each submission.<\/p>\n Since 31 October 2021, obliged entities<\/a><\/strong>, including banks, accounting firms, insurers and other entities applying customer due diligence measures<\/a><\/strong>, have been required to verify CRBR data.<\/p>\n This is another reason to keep CRBR data consistent with the actual situation. A bank or accounting firm may detect a discrepancy and trigger a review before you do.<\/p>\n The CRBR amendment is more than a formal change. Restricted public access, a new access process, stricter penalties and the duty to monitor data continuously require practical steps.<\/p>\n Do not treat these changes as a formality. Failure to meet the duties may lead to penalties of up to PLN 1,000,000 and personal criminal and civil liability.<\/p>\n Need help adapting your business to the applicable requirements?<\/p>\nHow can you access CRBR data based on a legitimate interest?<\/h2>\n
How to submit an application<\/h3>\n
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Deadlines and review rules<\/h3>\n
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Implementation timeline<\/h3>\n
What duties do businesses have?<\/h2>\n
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Penalties for incorrect CRBR data<\/h2>\n
Administrative penalty<\/h3>\n
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Personal liability<\/h3>\n
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Obliged entities must verify the data<\/h2>\n
What does this mean in practice?<\/h3>\n
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Summary: what should you do now?<\/h2>\n
Minimum implementation checklist<\/h3>\n
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