Obliged institutions — is your company on the list?

The full list of obliged institutions (art. 2(1))

The table gives the point of the Act, the category, the threshold or key exclusion and the page covering that sector. The wording is abridged — the full text is in the consolidated Act.

The EUR 10,000 threshold is converted at the NBP average rate of the transaction day. "Linked transactions" means that splitting one payment into several smaller ones does not remove the duty.

The "non-obvious" obliged institutions

Most questions about the status come from businesses that do not see themselves as "financial":

• A shop, wholesaler, car dealer, developer — becomes an obliged institution to the extent it accepts or makes cash payments of EUR 10,000 or more for goods (pt 23). It is not about annual turnover but a single payment or several linked ones. A business that never takes such cash is outside the AML Act — but inside the sanctions act.
• A jeweller, gallery, antique shop, auction house — pt 24a covers trade and intermediation in art, collectibles and antiques with no threshold, and storage in free ports from EUR 10,000.
• A rental agent — pt 18 excludes only rental brokerage where the monthly rent is below EUR 10,000. Sales brokerage — always.
• Postal operators (pt 19) — in practice, money transfers.
• Foundations and associations — only when they accept or make cash payments from EUR 10,000.
• An accounting office keeping only simplified records — pt 15a covers tax records and returns too, not only full books. A one-person office is an obliged institution just like a firm with 50 staff.

What it means in practice: seven duties

There is no "light" version of the status. From the first day of an activity in the catalogue you owe:

1. the institution's risk assessment (art. 27) — written, updated every 2 years,
2. an internal procedure (art. 50),
3. financial security measures for clients (art. 33–37): identification, verification, beneficial owner, PEP, sanctions, monitoring,
4. appointed responsible persons (art. 6–8),
5. training (art. 52),
6. documentation kept for 5 years (art. 49),
7. reporting to GIIF and reporting CRBR discrepancies (art. 72–74, 86, 61a).

Each duty explained: The AML Act — seven duties. Practical guides: due diligence, client risk assessment, counterparty monitoring.

How to tell whether you are covered: five questions

1. Is your activity in the table above? What counts is the activity actually carried on, not the PKD code in CEIDG or KRS — although an inspector starts from the PKD.
2. Do you do it professionally and for a fee? A one-off favour with a friend's tax return is not "bookkeeping services"; regular client work is.
3. Do you take cash of EUR 10,000 or more for goods? If so — you are an obliged institution to that extent, whatever your sector.
4. Do you fall within an exclusion? Rentals below EUR 10,000, a single-insurer agent collecting no premiums, defence in proceedings — examples written into the Act.
5. Are you under another supervisor? An exchange office — the NBP President, a payment institution — KNF, a notary — the president of the court of appeal. That does not change the duties, but it changes who inspects and fines you.

If you answer "yes" to questions 1–3 and no exclusion applies — you are an obliged institution. In doubt, seek an individual legal opinion; GIIF also publishes communications and positions at gov.pl.

Changes to the catalogue

• Since 2025 — pt 27: credit servicers within the meaning of the Act of 20 December 2024 (implementing the credit servicers directive).
• Draft amendment (Sejm print no. 3163, September 2026) — the government bill implementing AMLD6 provides, among other things, a new SIGIIF IT system to which an obliged institution must obtain access before its first client relationship, CRBR access based on legitimate interest, and a narrower wording of pt 15a for bookkeeping services. The bill has not been passed — the table above is the law in force.
• From 10 July 2027 — the catalogue of obliged entities will be set directly by art. 3 of the AMLR regulation (EU) 2024/1624: it adds, among others, dealers in precious metals and stones and in high-value goods, crowdfunding service providers, investment migration operators, and from 2029 football clubs and agents. Details: AMLA and AMLR 2027.

Legal state: October 2026. Informational material, not legal advice.