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Beneficial owner — who it is and how to establish it.

art. 2(2)(1) of the Polish AML Act

Beneficial owner — who it is and how to establish it.

A natural person who controls the client: directly, indirectly or through other rights. The threshold is 25% of shares or votes — but that is only the start.

Sample report

The Verifykator report shows:
  • Sanctions: MSWiA, EU, OFAC
  • KNF warnings
  • Beneficial owners (CRBR)
  • Financials and filings
  • Bankruptcy, liquidation, KRZ
  • VAT status and accounts
  • Press coverage
  • 0–100 risk score and PDF

Money back if the report cannot be generated

For companies: the first 2 reports free (in Polish)

✓GDPR · servers in the EU✓Report in up to 3 minutes✓Przelewy24 payments✓PLN 39.36 incl. VAT
25%
Threshold of shares or votes
2 levels
Ownership structure by default
14 days
To file a change with the CRBR
PLN 1M
Maximum fine for not filing

What the Act says

A beneficial owner is any natural person who directly or indirectly controls the client through rights that allow a decisive influence over its actions, or the person on whose behalf a relationship is entered into or a transaction carried out (art. 2(2)(1) of the AML Act). For a company — a legal person other than one listed on a regulated market — the Act names explicitly:

  • a natural person holding more than 25% of the total number of shares;
  • a person with more than 25% of the total votes, also as a pledgee, usufructuary or under agreements with other holders;
  • a person controlling a legal person or persons that together hold more than 25% of shares or votes;
  • a person exercising control within the meaning of accounting law (a parent entity);
  • where none of the above can be established and there is no suspicion of money laundering — the person holding a senior management position.

Separate definitions cover trusts (settlor, trustee, protector, beneficiary) and natural persons running a business — there the owner is the trader, unless something points to control by someone else.

Companies entered in KRS file their owners with the Central Register of Beneficial Owners (art. 58–59) and update the filing within 14 days of a change. An obliged entity that finds a discrepancy between the CRBR and its own findings reports it to the authority keeping the register (art. 61a). Full text: isap.sejm.gov.pl.

Step by step

How to establish the owner in five steps.

  1. Shareholders from KRS

    Pull the current extract and the shareholder list. Every natural person with more than 25% of shares or votes is an owner. Check preferred shares and shareholder agreements where disclosed.

  2. If a shareholder is a company — go up

    For each corporate shareholder pull its own shareholders and multiply: 60% × 50% = 30%, above the threshold. Repeat until you reach natural persons or a listed company. For a foreign shareholder, use its home register.

  3. Compare with the CRBR

    Set your own analysis against the CRBR filing: the same people, the same holdings, the same nature of rights. No filing at all is a signal too.

  4. Sanctions and PEP for each one

    Screen every established owner against sanctions lists and for PEP status — whether or not they appear in the CRBR.

  5. Discrepancy? Report it

    If your findings differ from the CRBR, ask the client to explain, and as an obliged entity report the discrepancy with reasons (art. 61a). Record the result and date in the file.

A worked example

Client: Alfa sp. z o.o. Direct shareholders: Beta sp. z o.o. (60%) and Jan K. (40%). Beta is owned by Gamma s.a. (50%) and Anna M. (50%). Gamma is owned by Piotr W. (80%) and Marta L. (20%).

PersonPathEffective holdingOwner?
Jan K.direct 40%40%yes
Anna M.Beta 60% × 50%30%yes
Piotr W.Beta 60% × Gamma 50% × 80%24%not by shares — check control over Gamma
Marta L.Beta 60% × Gamma 50% × 20%6%no

Piotr W. holds 24% effectively, but controls Gamma (80%), and Gamma co-controls Beta, which holds 60% of Alfa. If the Gamma or Beta agreements give him the say over their votes, he is an owner through "control over a legal person". The arithmetic is the start; rights are the second half.

Common mistakes

Four mistakes in establishing the owner.

Each ends with the wrong person in the file — or no person at all.

1
Stopping at the first level
A corporate shareholder is not the end of the analysis
Holdings are multiplied through the whole chain
2
A board member "for lack of a better option"
Allowed only when there truly is no one above 25% and no control
When the owner is known, naming the board is a filing error
3
Ignoring indirect rights
Pledge, usufruct of shares, shareholder agreements, the right to appoint the board
Control without shares also makes an owner
4
Not reporting a discrepancy
An obliged entity has the duty under art. 61a
Not reporting is a separate breach at an inspection

How the report helps

The complete AMLA dossier shows the CRBR owners and the KRS shareholders side by side and unfolds the ownership structure to two levels by default, computing effective holdings through the chain. Discrepancies between the registers — a different person, a different holding, no filing, an outdated filing — are flagged in the "Structure and UBO" domain with points and the source, and for each one the report attaches a draft discrepancy notice to the CRBR.

Every established person is screened against sanctions lists; obliged entities that make a declaration also see PEP and RCA status. Persons whose KRS data is published in masked form are not screened automatically, and the report says so. A foreign shareholder is shown with its name and country; its further structure is not unfolded — that has to be established with the client.

See also: CRBR lookup, beneficial owners in the report, customer identification. Scoring rules: methodology.

Legal status as of October 2026. Information only, not legal advice.

Pricing

Structure and owners are in the full report.

The free check shows the company's register data. Shareholders from KRS, owners from the CRBR, effective holdings and discrepancies are in the AMLA dossier.

Free
Basic check
PLN 0
No account, no card — NIP and e-mail
Included:
KRSName, KRS number, status, legal form, address
Included:
White List of VAT taxpayersVAT status, REGON, bank accounts reported to the Ministry of Finance
Included:
GUS REGONMain PKD code, employee range, registration date
Included:
VIESEU VAT number validity
Not included:
Sanctions, PEP and KNF warnings
Not included:
Beneficial owners (CRBR)
Not included:
Financials, insolvency, KRZ
Not included:
0–100 score and PDF report
Full report
Complete AMLA dossier
PLN 39.36
PLN 32.00 + 23% VAT · packs of 5/20/100 from PLN 9.99 a report
Included:
Everything in the basic checkKRS, VAT White List, GUS REGON, VIES
Included:
Sanctions and warningsOpenSanctions (incl. the Polish MSWiA list), EU list, OFAC SDN, KNF — the company and its owners
Included:
Beneficial ownersCRBR and shareholders from KRS
Included:
FinancialsRevenue, net result, equity, filing dates, MSiG and KRZ notices
Included:
ProceedingsBankruptcy, liquidation, restructuring, compulsory administration, UOKiK decisions
Included:
ReputationPress coverage, domain age, BDO register
Included:
0–100 score in 5 domainsPDF report by e-mail, recommended next steps
FAQ

Questions about the beneficial owner.

Yes — the trader themselves, unless there are indications that someone else is in control. A sole trader files nothing with the CRBR; you identify the owner from CEIDG.

Establish the owner by NIP.

Shareholders from KRS, owners from the CRBR, effective holdings and discrepancies — in one PDF report, in up to 3 minutes.

Complete AMLA dossier · PLN 39.36 incl. VAT · Przelewy24 · PDF by e-mail