Entrepreneur, keep an eye on the deadline for entry in the Central Register of Beneficiaries (CRBR)!
Entry in the Central Register of Beneficial Owners is an obligation for every company, and more recently also for cooperatives, associations and foundations. Failure to comply with the notification obligation is subject to very high fines, which can reach up to PLN 1 million.
For many entities, it is problematic to determine the beginning and end date of the deadline for notifying the entity (or changes in its data) to the CRBR. As a rule, the deadline is always seven working days (i.e. we do not include weekends and other public holidays).
In the case of the first entry to the National Court Register (registration) and entries of constitutive nature (i.e. entries required for the validity of a given change, such as amendment of the articles of association or share capital increase), the deadline is always counted from the date of registration of a given activity in the National Court Register. It is indicated directly in the KRS printout and in the entry decision.
In the case of a declaratory entry into the National Court Register (i.e. one that merely discloses changes that are already binding, e.g. changes to the personal composition of the management board or a change of shareholders), the deadline of seven working days counts from the date of the act constituting the basis for the entry (analogically, adoption of a resolution on appointment of a given person to the management board or the date of a share sale agreement).
Should you have any further doubts as to how the deadline for entry in the CRBR is calculated, or any other commercial or business law deadlines, please feel free to contact me.