In-scope payment and crypto-asset service providers must maintain internal policies, procedures and controls to implement EU and national restrictive measures.
Supporting requirements
Read more scenario context
Establish risk-based remote-onboarding policies, management oversight and a documented assessment before implementing a new solution.
Supporting requirements
Use reliable remote evidence for identity and authority to act, and stop an unreliable remote process rather than accepting incomplete verification.
Preview of legislation and requirement mapping for Poland
Requirement
Source type
Authority
Supporting provision
Review pending
Apply CDD when establishing a relationship, at applicable occasional-transaction thresholds, on suspicion, and when prior identity data is doubtful.
legislation
Sejm / Kancelaria Sejmu, Polish Financial Supervision Authority
Article 35(1)(1)-(2), (5)-(6) and (2); Article 38(1)-(2); UKNF information updated 23 June 2026, introductory paragraph and point 2 (authorisation boundary)
Review pending
Establish the individual's name, citizenship, PESEL or date of birth if no PESEL, country of birth, and identity-document series and number.
legislation
Sejm / Kancelaria Sejmu
Article 36(1)(1)(a)-(f); Article 34(2)
Review pending
Identify the representative of a legal person or organisational unit. Where a person is authorised to act for any customer, collect the fuller authorised-person identity particulars and verify both identity and authority.
legislation
Sejm / Kancelaria Sejmu
Article 36(1)(2)(e), read with (1)(1)(a) and (c); Article 36(3), read with (1)(1)(a)-(d); Article 34(2); Article 37(1)
Review pending
Verify customer, representative and beneficial-owner identity using reliable independent evidence; do not rely only on a beneficial-owner register.
Do not establish a relationship or execute the specified transactions when an Article 34(1) measure cannot be applied; terminate existing relationships and assess reporting.
legislation
Sejm / Kancelaria Sejmu
Article 41(1)-(3)
Previous checked narrative
Baseline reading under review
Individual onboarding separates prescribed identity data from the evidence used to verify it. Establish name, citizenship, PESEL or date of birth where no PESEL exists, country of birth and identity-document details; the residential-address field is qualified by whether that information is held. Sole traders have additional business particulars. Check identity using reliable independent evidence, and verify any representative's identity and authority. The normal gate is verification before the relationship or transaction, with timing exceptions available only under their specific statutory conditions. Supporting requirements
For an in-scope Polish institution, establishing a relationship triggers due diligence independently of occasional-transaction thresholds. Assess the particular relationship as well as the institution's wider exposures, using purpose, expected activity and relevant customer, product and geographical factors to determine the measures needed. Higher risk calls for enhanced diligence, while simplified treatment requires confirmed lower risk. National and EU assessments may inform the institutional assessment, but the provision does not require copying their scores into the customer's rating. Supporting requirements
legislation / Review pending
Apply CDD at statutory triggers
What this requires
Apply CDD when establishing a relationship, at applicable occasional-transaction thresholds, on suspicion, and when prior identity data is doubtful.
RegCanary explanation
General occasional-transaction CDD applies at EUR 15,000 or more, including apparently linked operations; funds transfers trigger it above EUR 1,000. For Article 2(1)(12) entities, occasional virtual-currency transactions trigger it at EUR 1,000 or more. Refresh existing-client CDD according to risk, especially changed relationship circumstances, customer/beneficial-owner data, or the specified legal obligation to recontact the customer.
Applicability
Business lines
all
Customer types
all
Stages
onboarding, ongoing, investigation, offboarding
Supporting provision
Article 35(1)(1)-(2), (5)-(6) and (2); Article 38(1)-(2); UKNF information updated 23 June 2026, introductory paragraph and point 2 (authorisation boundary)
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: changed, document d80952d9fe69
: unchanged, document c56187ac322d
Source changed
Polish Financial Supervision Authority
Source diagnostics
Lifecycle
Source changed
Language
pl
Retrieved
11 Sept 2026
Extraction
captured
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
requires-revalidation
Type
guidance
Version
Updated 23 June 2026; introductory paragraph and points 1-3
Original: data/country-handbook-evidence/pl/knf-mica-transition-20260623-delivery.html. Native public guidance states the Article 143(3) transition ends on 1 July 2026 and the Polish virtual-currency register is not MiCA authorisation. Point 3's statement about national implementing legislation is expressly dated June; it is not promoted into a verified September absence-of-law claim. This source does not establish a particular provider's permission.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: unchanged, document ac06f20aba55
: unchanged, document ac06f20aba55
: unchanged, document ac06f20aba55
: unchanged, document ac06f20aba55
: unchanged, document ac06f20aba55
Conditions
Applies only where the institution is an obliged institution under Article 2(1): banking/financial institutions (point 1), cooperative savings and credit unions and their national association (point 2), payment/e-money entities (point 3), investment/fund entities (points 4, 5 and 7), or the specified virtual-currency exchange, intermediation or account services (point 12). Product labels alone do not establish statutory scope; crypto does not mean every MiCA activity.
Thresholds are distinct from Article 72 reporting thresholds. Suspicion and doubts about identity are independent triggers, not subject to a monetary floor.
At investigation or offboarding, route the component duties only where an Article 35 trigger, still-pending CDD or final transaction requires them; those stage labels do not prescribe universal re-collection of customer data.
A Polish virtual-currency register entry is not MiCA authorisation and does not extend the transition beyond 1 July 2026, as UKNF's 23 June 2026 notice explains. National AML obligations and permission to provide a regulated service are separate questions; this handbook does not verify an individual provider's licence.
Exceptions
Article 38 permits omission of Article 34(1)(1)-(3) for e-money only when all five limiting conditions hold: non-reloadable instrument or EUR 150 monthly limit usable only in Poland; stored value at most EUR 150; goods/services use only; no funding with e-money issued without CDD; and ongoing analysis/monitoring. It is unavailable for redemption/cash withdrawal above EUR 50 or a remote payment above EUR 50. Monitoring remains required. Other sector-specific Article 35 thresholds are outside this financial-sector selection.
Evidence diagnostics
Record ID
pl-cdd-triggers
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
cdd
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Collect the prescribed individual identity data
What this requires
Establish the individual's name, citizenship, PESEL or date of birth if no PESEL, country of birth, and identity-document series and number.
RegCanary explanation
Record residential address when held. For a sole trader also establish business name, NIP and principal business address. These are the customer's identity particulars; a sole trader is not treated as a separate company merely because a business name is used. Identity-data collection is distinct from the documents or other evidence used to verify it. Any authorised representative must also be identified and their identity and authority verified.
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: changed, document d80952d9fe69
: unchanged, document c56187ac322d
Conditions
Applies only where the institution is an obliged institution under Article 2(1): banking/financial institutions (point 1), cooperative savings and credit unions and their national association (point 2), payment/e-money entities (point 3), investment/fund entities (points 4, 5 and 7), or the specified virtual-currency exchange, intermediation or account services (point 12). Product labels alone do not establish statutory scope; crypto does not mean every MiCA activity.
Applies to a natural-person customer, including a sole trader. Company and trust identity requirements depend on their separate legal form; do not import this entire personal-data list into every beneficial-owner enquiry.
At investigation or offboarding, collect or refresh these particulars only where the routed Article 35 trigger, incomplete CDD or final transaction requires it.
Exceptions
Residential address is qualified by possession of the information; do not rewrite it as an unqualified statutory collection duty. Date of birth substitutes for PESEL only where no PESEL was assigned.
Evidence diagnostics
Record ID
pl-individual-identification
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
cdd
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Distinguish an entity's representative from a person authorised to act
What this requires
Identify the representative of a legal person or organisational unit. Where a person is authorised to act for any customer, collect the fuller authorised-person identity particulars and verify both identity and authority.
RegCanary explanation
For the representative identified as part of an entity's identity, Article 36(1)(2)(e) specifies name and surname, PESEL or birth date if no PESEL has been assigned, and country of birth. Article 36(3) separately requires the name, citizenship, PESEL or substitute birth date, country of birth, and identity-document series and number of a person authorised to act for the customer. Article 34(2) requires verifying that person's identity and authority. If the same person performs both roles, apply the fuller authorised-person duties as well; the shorter entity-representative list does not displace them. Being named as a beneficial owner is not, by itself, proof of authority to act.
Applicability
Business lines
all
Customer types
all
Stages
onboarding, ongoing, investigation, offboarding
Supporting provision
Article 36(1)(2)(e), read with (1)(1)(a) and (c); Article 36(3), read with (1)(1)(a)-(d); Article 34(2); Article 37(1)
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: changed, document d80952d9fe69
: unchanged, document c56187ac322d
Conditions
Applies only where the institution is an obliged institution under Article 2(1): banking/financial institutions (point 1), cooperative savings and credit unions and their national association (point 2), payment/e-money entities (point 3), investment/fund entities (points 4, 5 and 7), or the specified virtual-currency exchange, intermediation or account services (point 12). Product labels alone do not establish statutory scope; crypto does not mean every MiCA activity.
The shorter representative list arises only for a legal-person or organisational-unit customer. The authorised-person duties apply whenever someone is authorised to act for an individual, entity or trust-related customer.
Check the person's actual role and legal authority. The provisions do not require treating every shareholder, trustee, board member or beneficial owner as the authorised person solely because of that title.
At investigation or offboarding, identify or re-verify the person and authority only where the routed Article 35 trigger, incomplete CDD or final transaction requires it.
Exceptions
The authorised-person particulars in Article 36(3) do not include an unconditional residential-address requirement. Additional information may still be justified by other duties or the circumstances.
No single power-of-attorney form, notarisation method or certificate is mandated for all cases by these provisions. Such documents may be evidence of authority where appropriate, but must not be described as universal statutory identity fields.
Evidence diagnostics
Record ID
pl-representative-identification
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
cdd
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Verify independently before the relationship or transaction
What this requires
Verify customer, representative and beneficial-owner identity using reliable independent evidence; do not rely only on a beneficial-owner register.
RegCanary explanation
Confirm the prescribed identity particulars using an identity document, a document containing current information from the appropriate register, or other reliable independent documents, data or information, including available electronic identification or trust services. Verify an authorised person's identity and authority to act. For entities within Article 39(1a), obtain BO-registration confirmation or an extract from the relevant BO register, but do not rely solely on that register for beneficial-owner checks. Documentary examples are not a universal mandatory pack: a particular certificate, utility bill, notarised copy or trust deed is not prescribed for every customer by these provisions. The usual gate is customer and beneficial-owner verification before the relationship or occasional transaction.
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: changed, document d80952d9fe69
: unchanged, document c56187ac322d
Conditions
Applies only where the institution is an obliged institution under Article 2(1): banking/financial institutions (point 1), cooperative savings and credit unions and their national association (point 2), payment/e-money entities (point 3), investment/fund entities (points 4, 5 and 7), or the specified virtual-currency exchange, intermediation or account services (point 12). Product labels alone do not establish statutory scope; crypto does not mean every MiCA activity.
The duty to establish identity and authority is separate from the choice of satisfactory evidence. For example, relevant register information or an independently corroborated mandate may help verify authority, and reliable constitutive material may help establish trust roles; their usefulness depends on authenticity, independence and the legal form.
At investigation or offboarding, verify only where the routed Article 35 trigger, incomplete CDD or final transaction requires it; the stage labels are not a universal repeat-verification rule.
The specific BO-register evidence duty concerns entities listed in Article 58 or subject to relevant Member State BO-registration rules. Article 58(6) covers trusts whose trustees or equivalent persons reside or have their seat in Poland, or establish a relationship or acquire real estate in Poland for the trust. Do not presume every foreign arrangement must have a Polish company-register number.
Exceptions
Article 39(2) permits completion during establishment only for business continuity and low ML/TF risk, as soon as possible. Article 39(3) permits specified institutions to open the listed accounts only if customer/BO CDD precedes transactions through them. For class-defined trust beneficiaries, Article 39(4) requires enough class information to identify the beneficiary at payout or exercise of rights.
Article 34(4) permits copying identity documents for CDD; it is not a universal requirement to retain a passport copy for each customer or beneficial owner. Record the measures taken and distinguish information collected from the evidence supporting verification.
Evidence diagnostics
Record ID
pl-identity-verification
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
verification
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Do not proceed where required CDD cannot be applied
What this requires
Do not establish a relationship or execute the specified transactions when an Article 34(1) measure cannot be applied; terminate existing relationships and assess reporting.
RegCanary explanation
Article 41 separately requires considering whether inability to apply CDD warrants an Article 74 or Article 86 notification. Failure is not automatically proof of money laundering, and high risk alone is not the statutory inability trigger. Document the failed measure, decision and reporting assessment.
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: changed, document d80952d9fe69
: unchanged, document c56187ac322d
Conditions
Applies only where the institution is an obliged institution under Article 2(1): banking/financial institutions (point 1), cooperative savings and credit unions and their national association (point 2), payment/e-money entities (point 3), investment/fund entities (points 4, 5 and 7), or the specified virtual-currency exchange, intermediation or account services (point 12). Product labels alone do not establish statutory scope; crypto does not mean every MiCA activity.
Triggered by inability to apply a required Article 34(1) measure, after accounting for any applicable statutory qualification.
Exceptions
Article 41(3) contains a litigation/legal-advice carve-out for Article 2(1)(14) professionals; it is not a general financial-institution exemption.
Evidence diagnostics
Record ID
pl-cdd-failure
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
verification
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Report suspicious circumstances promptly and protect confidentiality
What this requires
Notify GIIF immediately of circumstances indicating suspected ML/TF, no later than two working days after the institution confirms the suspicion.
RegCanary explanation
The Article 74 notification includes client and held third-party identity details, assets/location, account information, held transaction/attempt information, relevant EEA cross-border country, risk/predicate-offence information and reasons. Submit electronically under Article 79 and provide the identifying institution form for first reporting under Article 77. Preserve Article 54 confidentiality concerning reports and planned/ongoing analysis. Assess this route even where no particular transaction is identified; the Article 86 route addresses a specified transaction or assets. A threshold report or quarterly statistical return does not discharge a suspicion-reporting obligation.
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: changed, document d80952d9fe69
: unchanged, document c56187ac322d
Conditions
Applies only where the institution is an obliged institution under Article 2(1): banking/financial institutions (point 1), cooperative savings and credit unions and their national association (point 2), payment/e-money entities (point 3), investment/fund entities (points 4, 5 and 7), or the specified virtual-currency exchange, intermediation or account services (point 12). Product labels alone do not establish statutory scope; crypto does not mean every MiCA activity.
Do not confuse Article 74 with the immediate specific-transaction/asset route under Article 86. Two working days is an outer limit, not a permission to defer an immediate report.
Exceptions
Article 75 protects specified litigation/legal-advice information for Article 2(1)(14) professionals, not financial institutions generally. Article 54(2)-(3) contains narrowly conditioned information-sharing rules; group membership alone is not unrestricted permission to disclose.
Evidence diagnostics
Record ID
pl-suspicion-report
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
monitoring
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Report suspect transactions/assets and observe hold rules
What this requires
Immediately notify GIIF electronically of reasonable suspicion concerning a specific transaction or assets; observe the statutory non-execution and blocking rules.
RegCanary explanation
Provide the held suspicion information and planned transaction time. Pending a GIIF demand/release, refrain from the transaction or other debits on the relevant account for up to 24 hours from receipt confirmation. A GIIF demand under Article 86(5) can hold/block for up to 96 hours measured from that same confirmation, not 24 plus 96. Act immediately on the demand and respect later competent orders.
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: changed, document d80952d9fe69
: unchanged, document c56187ac322d
Conditions
Applies only where the institution is an obliged institution under Article 2(1): banking/financial institutions (point 1), cooperative savings and credit unions and their national association (point 2), payment/e-money entities (point 3), investment/fund entities (points 4, 5 and 7), or the specified virtual-currency exchange, intermediation or account services (point 12). Product labels alone do not establish statutory scope; crypto does not mean every MiCA activity.
Keep GIIF receipt-confirmation timestamp. Article 86 and GIIF-initiated Article 87 have different timing anchors; this record describes Article 86 only.
When calculating the periods in Articles 86(4)-(5), 87(2) and 89(3), Article 92 excludes Saturdays and statutory holidays. This exclusion concerns those specified periods, not every deadline or the separate Banking Law and Credit Union Act 72-hour blocks.
Exceptions
GIIF may release the initial hold under Article 86(6); later prosecutor orders can supersede it. If pre-transaction notification was impossible, Article 90(1) requires immediate post-transaction notification with reasons. Article 86(12) permits the specified limited disclosure of a GIIF demand on the customer's request. Historical notice 21 does not create an 11:00-14:00 reporting deadline.
Evidence diagnostics
Record ID
pl-urgent-report-and-hold
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
monitoring
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Freeze listed terrorist-related assets and notify GIIF
What this requires
Apply the AML Act's targeted restrictions to persons/entities on Article 118 lists: freeze assets and prevent direct or indirect availability.
RegCanary explanation
Article 117 covers assets owned, held or directly/indirectly controlled, and benefits derived from them. Apply restrictions without first notifying the listed person/entity. Provide GIIF all held information about the freeze/non-availability immediately and no later than two working days after the action.
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: changed, document d80952d9fe69
: unchanged, document c56187ac322d
Conditions
Applies only where the institution is an obliged institution under Article 2(1): banking/financial institutions (point 1), cooperative savings and credit unions and their national association (point 2), payment/e-money entities (point 3), investment/fund entities (points 4, 5 and 7), or the specified virtual-currency exchange, intermediation or account services (point 12). Product labels alone do not establish statutory scope; crypto does not mean every MiCA activity.
Limited to the Article 118 terrorist-related lists, including the GIIF-published UN-based lists and the Article 120 list. Separate EU and MSWiA national sanctions regimes can also apply but are not fully mapped here.
Exceptions
Article 119(3) addresses GIIF release where the affected person/entity is not on the Article 118 lists. Do not generalise this into a power to release assets subject to another sanctions regime; derogations and competent-authority permissions require separate review.
Evidence diagnostics
Record ID
pl-tf-asset-freeze
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
monitoring
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Apply enhanced measures to higher-risk cases
What this requires
Use enhanced CDD for higher ML/TF risk, including the mandatory high-risk-third-country cases.
RegCanary explanation
For relationships/transactions involving a Commission-identified high-risk third country, obtain additional customer/BO and relationship information, source of wealth and funds for customer and BO, reasons/circumstances of transactions, senior-management approval for relationship establishment/continuation, and more intensive monitoring. Article 43 flags private banking, complex ownership and unmitigated non-face-to-face activity among risk indicators; an indicator is not an automatic universal prohibition.
Applicability
Business lines
all
Customer types
all
Stages
all
Supporting provision
Article 43(1)-(2); Article 44(1)-(3); Article 42(1) and (3)
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: changed, document d80952d9fe69
: unchanged, document c56187ac322d
Conditions
Applies only where the institution is an obliged institution under Article 2(1): banking/financial institutions (point 1), cooperative savings and credit unions and their national association (point 2), payment/e-money entities (point 3), investment/fund entities (points 4, 5 and 7), or the specified virtual-currency exchange, intermediation or account services (point 12). Product labels alone do not establish statutory scope; crypto does not mean every MiCA activity.
Use the applicable Commission delegated list at decision time; this handbook does not embed a verified current country list. Additional transaction countermeasures and correspondent rules in Articles 44a-45 need separate review.
Exceptions
Article 44(2)-(3) removes the automatic trigger based solely on location for specified branches/majority-owned subsidiaries applying group procedures; risk assessment still governs. Simplified CDD requires confirmed lower risk under Article 42 and is unavailable on suspicion or identity doubts.
Evidence diagnostics
Record ID
pl-enhanced-due-diligence
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
risk
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Identify PEP connections and apply enhanced controls
What this requires
Use risk-based procedures to identify PEP customers/beneficial owners and apply the statutory relationship controls.
RegCanary explanation
Obtain senior-management approval to establish or continue a PEP relationship, establish the customer's source of wealth and source of assets involved, and intensify monitoring. Apply the provisions correspondingly to family members and known close associates. After a person leaves office, retain risk-sensitive measures until the higher risk ceases and for at least 12 months.
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: changed, document d80952d9fe69
: unchanged, document c56187ac322d
Source check failed
Minister of Finance / Sejm ELI
Source diagnostics
Lifecycle
Source check failed
Language
pl
Retrieved
11 Sept 2026
Extraction
captured
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
unvalidated
Type
legislation
Version
Dz.U. 2025 poz. 502; consolidated regulation of 27 July 2021
Original captured at data/country-handbook-evidence/pl/D20250502-pep.pdf; 8 pages, Poppler extraction inspected. Sections 1-2, including selected positions in points 1-30 and 38-45, checked against the statutory PEP definition. Underlying-act metadata at https://api.sejm.gov.pl/eli/acts/DU/2021/1381 identifies this as the latest consolidation at inspection; metadata original retained as pep-underlying-delivery.json. The older 2023 consolidation is not used as current proof. This is a list of domestic functions, not a current register of office-holders. Publication is not treated as a new commencement date.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document 58af8da27d2b
: unchanged, document 58af8da27d2b
: unchanged, document 58af8da27d2b
: unchanged, document 58af8da27d2b
: unchanged, document 58af8da27d2b
Conditions
Applies only where the institution is an obliged institution under Article 2(1): banking/financial institutions (point 1), cooperative savings and credit unions and their national association (point 2), payment/e-money entities (point 3), investment/fund entities (points 4, 5 and 7), or the specified virtual-currency exchange, intermediation or account services (point 12). Product labels alone do not establish statutory scope; crypto does not mean every MiCA activity.
Screening must include beneficial owners, not only the named customer. Apply statutory PEP/family/associate definitions and relevant official domestic position lists; no live list is embedded here.
The statutory definition concerns prominent public functions and excludes intermediate and junior positions. The current domestic schedule includes specified national, regional and local offices and state-linked management functions; it is not a list of every public employee or current office-holder.
Family means spouse or cohabiting partner, children and their spouses/cohabiting partners, and parents. Known close associates include joint beneficial owners or other close business relationships, and sole beneficial owners of entities known to have been established for the PEP's benefit; do not substitute an unlimited family or social-contact category.
Exceptions
A written/documentary client declaration under Article 46(1) is an available method, not a mandatory sole method. Leaving office does not automatically end controls at 12 months. Insurance-specific paragraphs 3-4 are outside this record.
Evidence diagnostics
Record ID
pl-pep-controls
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
risk
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Document institution-wide and customer risk separately
What this requires
Assess institutional ML/TF risk and individual relationship/transaction risk, and scale CDD to the documented assessment.
RegCanary explanation
The institution-wide assessment must consider customers, countries/geographies, products, services, transactions and delivery channels; retain it on paper or electronically and update when necessary, at least every two years. Individual risk also considers account purpose, assets/transaction values, and the purpose, regularity and duration of the relationship. Article 27(2) permits use of the NRA and EU assessment; it does not mandate copying their scores.
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Latest assessment on this official index at retrieval is 2023. This is a bounded publication check, not proof that no other official update exists. Index identifies main report and Annexes 1-3. Original: data/country-handbook-evidence/pl/giif-nra-index.html. Re-fetched at 2026-09-10T20:38:36.949Z with the identical checksum; the 2023 assessment remains the latest listed. Fresh original: data/country-handbook-evidence/pl/giif-nra-index-coverage.html.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: unchanged, document 68532ee14306
: unchanged, document 68532ee14306
: unchanged, document 68532ee14306
: unchanged, document 68532ee14306
: unchanged, document 68532ee14306
Conditions
Applies only where the institution is an obliged institution under Article 2(1): banking/financial institutions (point 1), cooperative savings and credit unions and their national association (point 2), payment/e-money entities (point 3), investment/fund entities (points 4, 5 and 7), or the specified virtual-currency exchange, intermediation or account services (point 12). Product labels alone do not establish statutory scope; crypto does not mean every MiCA activity.
Proportionate to the institution's nature and size. The 2023 NRA is the latest listed on the inspected GIIF index, not a substitute for current institution/customer evidence.
Article 43(2)(9) identifies new products, services, distribution channels and technologies as possible higher-risk circumstances. Assess their relevance; the cited provision does not create an automatic prohibition or a fixed pre-launch approval deadline.
Exceptions
The two-year minimum refresh rule is for the institution-wide assessment; it is not a universal customer-review interval.
Evidence diagnostics
Record ID
pl-risk-assessments
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
risk
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Assign AML accountability and maintain approved procedures
What this requires
Appoint responsible senior management and a management-level compliance employee; maintain approved AML procedures and relevant staff training.
RegCanary explanation
Where a management board or equivalent exists, designate one member responsible for implementation. The Article 8 employee also handles specified notifications. Keep the Article 50 procedure under review, obtain senior-management approval before use or change, and provide role-relevant AML/data-protection training.
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: changed, document d80952d9fe69
: unchanged, document c56187ac322d
Conditions
Applies only where the institution is an obliged institution under Article 2(1): banking/financial institutions (point 1), cooperative savings and credit unions and their national association (point 2), payment/e-money entities (point 3), investment/fund entities (points 4, 5 and 7), or the specified virtual-currency exchange, intermediation or account services (point 12). Product labels alone do not establish statutory scope; crypto does not mean every MiCA activity.
The Article 50(2) procedure must also cover internal control or supervision of compliance, CRBR discrepancy records and difficulties verifying beneficial owners, including the documented senior-management fallback where used.
Exceptions
For a person conducting business alone, Article 9 allocates the Article 6 and 8 functions to that person; Article 52(3) adapts training to sole traders.
Evidence diagnostics
Record ID
pl-aml-governance
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
requirements
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Report qualifying transactions above EUR 15,000
What this requires
Where an institution performs a qualifying Article 72 funds-deposit/withdrawal, transfer or foreign-exchange operation above EUR 15,000, report it to GIIF within seven days of the relevant statutory event, subject to the statutory exclusions.
RegCanary explanation
Article 72(1) covers received deposits/made withdrawals of funds and executed funds transfers; paragraph 2 also covers inbound foreign transfers where the institution is the recipient's payment-service provider. Paragraph 3 separately covers foreign-exchange purchase/sale or intermediation. Report electronically under Article 78 with the institution identifying form under Article 77 when first fulfilling the duty. GIIF notice 53 explains that a recipient's payment-service provider must still report a qualifying foreign-origin transfer routed through a domestic intermediary; the domestic-transfer exception does not convert that foreign transfer into an exempt domestic one. A provider acting only as that intermediary does not report receipt and forwarding under this recipient-provider limb, but its other reporting duties remain. Using a reporting intermediary under Article 73 does not remove the institution's responsibility.
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Full substantive HTML read; only the recipient-provider Article 72(2) reporting clarification is adopted, checked against current Polish Article 72. The notice's references to Regulation 2015/847 are historical citations, not a confirmation that that EU Regulation remains applicable. Its linked technical materials and the replacement EU transfer regime are not validated here. Original: data/country-handbook-evidence/pl/giif-reporting-53-coverage.html.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: unchanged, document dde88f84d51b
: unchanged, document dde88f84d51b
: unchanged, document dde88f84d51b
: unchanged, document dde88f84d51b
: unchanged, document dde88f84d51b
Conditions
Applies only where the institution is an obliged institution under Article 2(1): banking/financial institutions (point 1), cooperative savings and credit unions and their national association (point 2), payment/e-money entities (point 3), investment/fund entities (points 4, 5 and 7), or the specified virtual-currency exchange, intermediation or account services (point 12). Product labels alone do not establish statutory scope; crypto does not mean every MiCA activity.
Only qualifying operations in Article 72, not every transaction above EUR 15,000. The seven-day clock follows the relevant paragraph 5 event, including making inbound funds available to the recipient. Strictly above EUR 15,000 differs from the general CDD trigger at EUR 15,000 or more. Virtual currency is not automatically foreign exchange or a funds transfer for this rule.
The foreign-origin/intermediary clarification applies only where the institution has the relevant payment-service-provider role. A virtual-currency exchange is not made a recipient's payment-service provider by this guidance.
Exceptions
Article 72(1) excludes institutions in Article 2(1)(11), (13)-(15a) and (18). Transfer exceptions in Article 72(1)(2)(a)-(f) cover the specified same-customer payment/deposit accounts, inbound domestic transfers from another obliged institution, own-account/own-benefit activity, public-finance-unit transactions, certain cooperative-bank reporting and security transfers. Article 180a excludes specified COVID-19 public-support transfers. Notarial reporting and its 2026 real-estate-data amendment are not this record.
Evidence diagnostics
Record ID
pl-threshold-reporting
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
monitoring
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Prevent tipping off and apply information-sharing exceptions narrowly
What this requires
Keep confidential the fact of reporting to GIIF or another competent authority under the reporting and hold chapters, and information about planned or ongoing ML/TF analysis.
RegCanary explanation
The duty binds the institution, its employees and other persons acting in its name and on its behalf. It protects the fact of reporting, not just the report's contents. Article 54(2) permits only the specified disclosures; the same-customer exception also requires the same transaction and the stated institutional, jurisdictional, secrecy and data-protection conditions. Article 54(3) requires sharing suspicions about criminal assets or terrorist financing within a group, but GIIF may order the suspicion to be kept confidential.
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: changed, document d80952d9fe69
: unchanged, document c56187ac322d
Conditions
Applies only where the institution is an obliged institution under Article 2(1): banking/financial institutions (point 1), cooperative savings and credit unions and their national association (point 2), payment/e-money entities (point 3), investment/fund entities (points 4, 5 and 7), or the specified virtual-currency exchange, intermediation or account services (point 12). Product labels alone do not establish statutory scope; crypto does not mean every MiCA activity.
The intra-group exception in Article 54(2)(1) concerns EU credit and financial institutions and qualifying third-country branches or majority-owned subsidiaries applying compliant group policies. Ordinary group membership does not establish that exception.
The same-customer/same-transaction route in Article 54(2)(4) lists Article 2(1)(1)-(5), (7)-(11), (13)-(15a), (17), (24) and (25). Virtual-currency institutions covered only by point 12 are not in that list; an additional qualifying legal status must be established before relying on it.
Exceptions
The professional-service exceptions in Article 54(2)(2)-(3) apply only to the listed professions, not financial institutions generally.
Under Article 86(12), at the specified customer's request the institution may disclose the fact of GIIF's hold/block demand. Article 87(4) applies that provision correspondingly. This is not permission to disclose the suspicion report or analysis generally.
Evidence diagnostics
Record ID
pl-report-confidentiality
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
requirements
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Respond to GIIF information and document requests
What this requires
Respond immediately to GIIF requests for held information or documents needed for its statutory tasks, observing any specified scope, form, deadline and requirement to obtain further information.
RegCanary explanation
Article 76 covers customer information, transaction particulars, assets and their location, ongoing CDD, and held IP addresses and connection times. GIIF may specify a deadline and form and may require further information to be obtained in connection with ongoing CDD or specified occasional transactions. Supply the response without charge and electronically under Article 79. The first fulfilment also requires the institution-identifying form under Article 77; relevant changes to that form must be updated immediately.
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: changed, document d80952d9fe69
: unchanged, document c56187ac322d
Conditions
Applies only where the institution is an obliged institution under Article 2(1): banking/financial institutions (point 1), cooperative savings and credit unions and their national association (point 2), payment/e-money entities (point 3), investment/fund entities (points 4, 5 and 7), or the specified virtual-currency exchange, intermediation or account services (point 12). Product labels alone do not establish statutory scope; crypto does not mean every MiCA activity.
This duty is triggered by a GIIF request. It does not make every listed item a universal onboarding field or require creation of unavailable historical logs merely because they appear in Article 76(1). A request to obtain additional information must be considered separately under paragraph 3.
Evidence diagnostics
Record ID
pl-giif-request-response
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
monitoring
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
No exceptions are recorded. This does not establish that none apply.
legislation / Review pending
Act on a GIIF-initiated transaction or account hold
What this requires
On receipt of a GIIF demand under Article 87, stop the transaction or block the account for the specified period, no longer than 96 hours from receiving that demand, subject to later competent orders.
RegCanary explanation
This route does not require a preceding notification by the institution. The demand specifies the assets subject to an account block. Record receipt and implement the demand using that timing anchor, which differs from the acknowledgement-based Article 86 clock. Article 87 applies the later-order provisions in Article 86(9)-(13): a prosecutor may order up to six months from receiving GIIF's notification and extend by up to a further six months. The statutory lapse rule depends on whether an asset-security or material-evidence order has been issued.
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: changed, document d80952d9fe69
: unchanged, document c56187ac322d
Conditions
Applies only where the institution is an obliged institution under Article 2(1): banking/financial institutions (point 1), cooperative savings and credit unions and their national association (point 2), payment/e-money entities (point 3), investment/fund entities (points 4, 5 and 7), or the specified virtual-currency exchange, intermediation or account services (point 12). Product labels alone do not establish statutory scope; crypto does not mean every MiCA activity.
The 96-hour limit here runs from receipt of the demand, not from an earlier report, and is not an additional 96 hours appended to an Article 86 hold.
When calculating the periods in Articles 86(4)-(5), 87(2) and 89(3), Article 92 excludes Saturdays and statutory holidays. This exclusion concerns those specified periods, not every deadline or the separate Banking Law and Credit Union Act 72-hour blocks.
Exceptions
Apply the actual scope and duration of subsequent competent orders. Limited disclosure at the customer's request follows Article 86(12) as applied by Article 87(4), not a general tipping-off exception.
Evidence diagnostics
Record ID
pl-giif-initiated-hold
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
monitoring
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
guidance / Review pending
Apply the requested financial-institution quarterly reporting conventions
What this requires
Where GIIF has required a financial-institution quarterly return, distinguish clients analysed from alerts or reports filed, and reconcile the return to the relevant quarter and current instructions.
RegCanary explanation
The public financial-institution FAQ says to count one client once despite repeated alerts and to include clients analysed by analysts or other designated staff regardless of whether a GIIF report followed. A zero for that analysis count requires a comment explaining it. New clients include those who both joined and left in the same quarter. The FAQ treats GIIF quarterly reporting and KNF prudential reporting as independent duties; neither replaces the other. These conventions apply to the requested return, not to all firms solely because they offer financial products.
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: changed, document d80952d9fe69
: unchanged, document c56187ac322d
Source check failed
Generalny Inspektor Informacji Finansowej (GIIF)
Source diagnostics
Lifecycle
Source check failed
Language
pl
Retrieved
10 Sept 2026
Extraction
captured
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
unvalidated
Type
reporting
Version
13 October 2025 version as labelled on the official index
Six-page Polish PDF extracted. Selected substantive Questions 3, 9, 10 and 15 checked for distinct-client counts, analysis outcome neutrality, zero explanations, independent KNF returns and same-quarter customer departures. Other examples and technical instructions are not generalised. The FAQ alone does not establish every addressee or current deadline. Original: data/country-handbook-evidence/pl/giif-quarterly-financial-faq-20251013.pdf.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document c3b29df3b1cd
: unchanged, document c3b29df3b1cd
: unchanged, document c3b29df3b1cd
: unchanged, document c3b29df3b1cd
: unchanged, document c3b29df3b1cd
Conditions
Applies only where the institution is an obliged institution under Article 2(1): banking/financial institutions (point 1), cooperative savings and credit unions and their national association (point 2), payment/e-money entities (point 3), investment/fund entities (points 4, 5 and 7), or the specified virtual-currency exchange, intermediation or account services (point 12). Product labels alone do not establish statutory scope; crypto does not mean every MiCA activity.
Confirm that GIIF has required this financial-institution return from the actual reporting entity and that its current form uses these questions. No universal financial-sector quarterly deadline or complete list of addressees is inferred from the FAQ.
Exceptions
Virtual-currency reporting uses a separate FAQ and instructions. Counting conventions for a statistical field do not redefine the customer or suspicious-reporting duties under the Act.
Evidence diagnostics
Record ID
pl-financial-quarterly-returns
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
monitoring
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
implementation / Review pending
Assess banking account and loan misuse scenarios
What this requires
Use relevant banking scenarios from the 2023 NRA to challenge the institution's assessment of account activity and loan repayment risk, alongside current customer and transaction evidence.
RegCanary explanation
The inspected examples include layering through connected company accounts under false commercial descriptions, mule or non-trading-company accounts, false identity documents, and loans repaid early with criminal funds. Where those features are relevant, an implementation approach is to compare expected activity with actual flows and examine the commercial purpose and source of repayment. The statutory duties are to assess and document risk and apply appropriate monitoring; the NRA does not require every early repayment or foreign company to be treated as suspicious.
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
335-page original retained. Coverage expansion inspected section 7.2.1, including paragraphs 587-588 (printed p.215), 603-604 (p.221), 610-611 (p.223) and 626 (p.225), using local Poppler extraction from the original. Selected banking, payment and virtual-currency vulnerabilities inform bounded implementation examples. Current means latest listed on the re-fetched GIIF NRA index, not current-year data or current law. Historic regulatory descriptions and universal claims about anonymity are not adopted. No numeric sector score has been mapped. Original: data/country-handbook-evidence/pl/giif-nra-2023.pdf.
197-page original retained. Coverage expansion inspected banking Tables 1-2 (pp.2-5), non-bank payment Tables 9-11 (pp.26-29), and virtual-currency Tables 32-34 (pp.83-86), using Poppler directly without modifying the handbook parser. Published examples selected for the three sector mappings have exact table/scenario locators. Not a full annex or all-sector review. NRA examples are not current regulatory-perimeter statements or automatic customer risk classifications. Original: data/country-handbook-evidence/pl/giif-nra-2023-annex-2.pdf.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document c6019b1fb4bf
: unchanged, document c6019b1fb4bf
: unchanged, document c6019b1fb4bf
: unchanged, document c6019b1fb4bf
: unchanged, document c6019b1fb4bf
Conditions
Applies only where the institution is an obliged institution under Article 2(1): banking/financial institutions (point 1), cooperative savings and credit unions and their national association (point 2), payment/e-money entities (point 3), investment/fund entities (points 4, 5 and 7), or the specified virtual-currency exchange, intermediation or account services (point 12). Product labels alone do not establish statutory scope; crypto does not mean every MiCA activity.
This mapping is for banking accounts and lending actually offered by the institution. It does not apply the bank-loan examples to a payment-only or virtual-currency-only provider.
The 2023 assessment is the latest listed on the inspected official index. Its historic case and market data do not establish current prevalence or a current country list; relevance must be assessed against the institution's own business.
Exceptions
The cited NRA scenarios are examples and contextual evidence, not mandatory document lists, automatic high-risk classifications, reporting triggers or prescribed monitoring thresholds. Assess the actual circumstances and current evidence.
Evidence diagnostics
Record ID
pl-nra-banking-scenarios
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
risk
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Report criminal misuse of banking activity and apply the separate blocking procedure
What this requires
Report reasonable suspicion of criminal misuse through the Banking Law route. A bank-initiated block is a power limited to suspected funds and 72 hours, with immediate prosecutor notification after blocking.
RegCanary explanation
Where banking activity is reasonably suspected of concealing criminal activity or serving fiscal crime or crime other than the specified money-laundering and terrorist-financing offences, notify the prosecutor, Police or another competent preliminary-investigation authority. Article 106a(1) sets no express numeric deadline. Where account funds are reasonably suspected of deriving from or relating to such fiscal or other crime, the bank may block only the suspected amount. Its block may last no longer than 72 hours from blocking; immediately after blocking, notify the prosecutor. Within that period the prosecutor decides whether to initiate proceedings and immediately informs the bank. If proceedings are initiated, an order may stop a specified transaction or block funds for up to six months from receipt of the post-block notification. A further order can extend the restraint for up to another six months. It lapses unless an asset-security or material-evidence order is made before expiry. Separately, paragraph 3a permits a prosecutor's order for up to six months even without the initial notification, including ML/TF cases; that paragraph does not use the post-block notification as its clock trigger.
Articles 41, 48k(2), 106 and 106a(1)-(9), pp.85, 100-101, 196-198 checked. The updated document also contains future amendments; no future bracket was used for these duties. Underlying-act metadata and amendment 846 Articles 7 and 16 inspected; that amendment changes disclosure provisions, not these reporting/hold rules. Commencement histories are not inferred from consolidation dates. Original: data/country-handbook-evidence/pl/D20260038Lj-20260911.pdf.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document 290405bcc096
: unchanged, document 290405bcc096
: unchanged, document 290405bcc096
: changed, document 290405bcc096
: unchanged, document bd3a91bb37d1
Conditions
Applies to banks and Polish operations of foreign-bank branches under Article 41 and credit-institution branches through Article 48k(2). Retail, corporate and private banking labels do not extend this rule to a non-bank provider.
The initial reporting duty and the bank's optional blocking power have different triggers. The bank's own block is limited to account funds covered by the suspicion; a prosecutor's order specifies its scope, manner and duration.
Exceptions
The initial other-crime route excludes Criminal Code Articles 165a and 299; the separate AML/CFT route remains applicable. The prosecutor's independent power in paragraph 3a expressly includes those offences.
Do not import the AML Act Article 89 mandatory 96-hour restraint, its calculation rules or its secondary GIIF transmission into this provision. A block order is appealable; criminal-procedure rules apply to matters not regulated here.
Evidence diagnostics
Record ID
pl-bank-other-crime-report
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
monitoring
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Apply the credit-union criminal-misuse reporting and blocking rules
What this requires
A credit union or its national association must report qualifying criminal misuse. The credit union's separate power to block suspected account funds is limited to 72 hours.
RegCanary explanation
Notify the prosecutor, Police or another competent preliminary-investigation authority where credit-union or national-association activity is reasonably suspected of concealing criminal activity or serving fiscal crime or crime other than Criminal Code Articles 165a and 299. Article 16(1) states no express numeric deadline. A credit union may block account funds reasonably suspected of deriving from or relating to the specified other crime, but only up to the suspected amount and for no longer than 72 hours from blocking. Immediately after blocking, notify the prosecutor. Within that period the prosecutor decides whether to initiate proceedings and immediately informs the credit union. On initiation, an order may stop a transaction or block funds for up to six months from receipt of that post-block notification, with a possible further six months. The restraint lapses unless an asset-security or material-evidence order is made before expiry. Paragraph 4 separately permits a prosecutor's order for up to six months without the initial notification, including ML/TF suspicions; it does not prescribe the post-block receipt trigger used by paragraph 7.
Articles 10, 15 and 16(1)-(10), pp.19, 25-27 checked in Polish. Article 16 distinguishes reporting by a credit union or the national association from account blocking by a credit union. Future amendments elsewhere in the PDF are not current duties; amendment 846 changes Article 9f, not Article 16. Original: data/country-handbook-evidence/pl/D20260595Lj-20260911.pdf.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document dba9c8c81c05
: unchanged, document dba9c8c81c05
: unchanged, document dba9c8c81c05
: changed, document dba9c8c81c05
: unchanged, document 413d52d3f779
Conditions
Applies to statutory cooperative savings and credit unions; paragraph 1 also names their national association. The account-blocking provisions refer to the credit union, not an automatic extension of its powers to the national association.
A banking product selection does not make an ordinary bank a credit union. Member eligibility is limited by Article 10: linked individuals, qualifying partnerships where the statute permits and all partners are individual members, and the specified organisations operating among members. Corporate selection does not establish general company eligibility.
Exceptions
Money laundering and terrorist financing remain subject to the separate Article 15/AML route; paragraph 4's independent prosecutor power nevertheless includes those offences.
Do not import Article 89's 96-hour restraint or GIIF order-copy trigger. A prosecutor's block is appealable and criminal-procedure rules govern unregulated matters.
No general eligibility for a trust to become a credit-union member is asserted.
Evidence diagnostics
Record ID
pl-credit-union-other-crime-report
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
monitoring
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Assess the purpose and intended nature of the relationship
What this requires
Assess the business relationship and, as appropriate, obtain information on its purpose and intended nature.
RegCanary explanation
Record a proportionate understanding of why the customer needs the service and how the relationship is intended to operate. The duty to assess is not optional; the extent of information obtained is qualified by the circumstances. Expected payment activity or investment purpose can be useful evidence, not a universally mandated questionnaire or fixed set of fields.
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: changed, document d80952d9fe69
: unchanged, document c56187ac322d
Conditions
Applies only where the institution is an obliged institution under Article 2(1): banking/financial institutions (point 1), cooperative savings and credit unions and their national association (point 2), payment/e-money entities (point 3), investment/fund entities (points 4, 5 and 7), or the specified virtual-currency exchange, intermediation or account services (point 12). Product labels alone do not establish statutory scope; crypto does not mean every MiCA activity.
At investigation or offboarding, reassess or obtain purpose information only where the routed Article 35 trigger, incomplete CDD or final transaction requires it.
Evidence diagnostics
Record ID
pl-relationship-purpose
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
cdd
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
No exceptions are recorded. This does not establish that none apply.
legislation / Review pending
Retain responsibility when relying on another institution's CDD
What this requires
Use qualifying third parties for customer and beneficial-owner identification/verification and relationship-purpose measures only on the statutory conditions.
RegCanary explanation
Ensure the third party provides the necessary information and documents, including copies of customer and beneficial-owner verification material, immediately on request. Reliance does not transfer responsibility. The third party must fall within Article 47(3), including equivalent CDD, record-keeping and supervision where applicable. This route concerns Article 34(1)(1)-(3), not delegation of ongoing monitoring.
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: changed, document d80952d9fe69
: unchanged, document c56187ac322d
Conditions
Applies only where the institution is an obliged institution under Article 2(1): banking/financial institutions (point 1), cooperative savings and credit unions and their national association (point 2), payment/e-money entities (point 3), investment/fund entities (points 4, 5 and 7), or the specified virtual-currency exchange, intermediation or account services (point 12). Product labels alone do not establish statutory scope; crypto does not mean every MiCA activity.
Applies when relying on another party's completed CDD; it is not mandatory to use such a party.
Exceptions
Do not rely on parties established in high-risk third countries, except qualifying branches or majority-owned subsidiaries of the institution or another EU obliged entity applying the Article 51 group procedure.
Article 47(5) permits recognition of specified same-group conditions only where its group procedures and group-level supervision conditions are met; responsibility and information access remain.
Evidence diagnostics
Record ID
pl-third-party-reliance
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
verification
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Control outsourced CDD under a written agreement
What this requires
CDD, ongoing transaction analysis and its documentation may be outsourced under the statutory written-contract arrangement; the obliged institution remains responsible.
RegCanary explanation
The person or organisation must act on the institution's behalf and be treated under the agreement as part of the obliged institution. This differs from reliance on a separate third party's CDD. Outsourcing does not remove the institution's responsibility for applying the measures.
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: changed, document d80952d9fe69
: unchanged, document c56187ac322d
Conditions
Applies only where the institution is an obliged institution under Article 2(1): banking/financial institutions (point 1), cooperative savings and credit unions and their national association (point 2), payment/e-money entities (point 3), investment/fund entities (points 4, 5 and 7), or the specified virtual-currency exchange, intermediation or account services (point 12). Product labels alone do not establish statutory scope; crypto does not mean every MiCA activity.
Applies only if CDD or ongoing analysis/documentation is outsourced. A technology supplier's product label does not establish this statutory arrangement.
Evidence diagnostics
Record ID
pl-cdd-outsourcing
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
verification
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
No exceptions are recorded. This does not establish that none apply.
legislation / Review pending
Apply group AML procedures and address third-country obstacles
What this requires
Institutions in a group must apply group procedures, including rules for sharing and protecting AML information.
RegCanary explanation
Ensure relevant third-country branches and majority-owned subsidiaries apply group procedures. Where the third country's requirements are less strict, apply Polish requirements, including data protection, to the extent local law permits. If local law prevents group procedures, require additional effective controls and inform GIIF and the competent Article 130(2) control bodies. Inadequate measures may lead to restrictions or termination of relationships or operations by the competent authority.
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: changed, document d80952d9fe69
: unchanged, document c56187ac322d
Conditions
Applies only where the institution is an obliged institution under Article 2(1): banking/financial institutions (point 1), cooperative savings and credit unions and their national association (point 2), payment/e-money entities (point 3), investment/fund entities (points 4, 5 and 7), or the specified virtual-currency exchange, intermediation or account services (point 12). Product labels alone do not establish statutory scope; crypto does not mean every MiCA activity.
Group membership and, for the overseas duties, the specified branch or majority-owned subsidiary relationship are required. This is not an unrestricted permission to share personal data.
The inspected national provision specifies no numerical notification deadline. Separate Regulation 2019/758 specifies obstacle-dependent notifications and countermeasures for institutions within its own credit/financial-institution scope.
Evidence diagnostics
Record ID
pl-group-controls
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
requirements
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
No exceptions are recorded. This does not establish that none apply.
legislation / Review pending
Provide confidential breach reporting and protect reporters
What this requires
Maintain an internal anonymous AML breach-reporting procedure and protect staff and other persons performing work against retaliation.
RegCanary explanation
Specify the recipient, reporting method, confidentiality and personal-data protections for reporters and persons accused, follow-up and a deletion deadline. Prevent retaliation, threats and deterioration of employment or other legal/factual conditions. Article 53a extends protection to persons carrying out the specified statutory reporting duties and permits retaliation reports to GIIF.
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: changed, document d80952d9fe69
: unchanged, document c56187ac322d
Conditions
Applies only where the institution is an obliged institution under Article 2(1): banking/financial institutions (point 1), cooperative savings and credit unions and their national association (point 2), payment/e-money entities (point 3), investment/fund entities (points 4, 5 and 7), or the specified virtual-currency exchange, intermediation or account services (point 12). Product labels alone do not establish statutory scope; crypto does not mean every MiCA activity.
Exceptions
The deletion deadline must be specified in the procedure; these provisions do not prescribe a universal numerical retention period for whistleblowing records.
This mapping concerns AML-specific protections, not every obligation under the separate general whistleblower legislation.
Evidence diagnostics
Record ID
pl-whistleblower-protection
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
requirements
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Add a countermeasure for high-risk-country transactions
What this requires
For a transaction connected with a Commission-identified high-risk third country, apply at least one additional statutory measure beyond the enhanced CDD package.
RegCanary explanation
Choose at least one of additional enhanced measures, intensified information/reporting obligations, or limiting the scope of the relationship or transactions. Record the applicable country link and selected measure. Article 44a does not make every such transaction suspicious or require an STR solely because of the country connection.
Applicability
Business lines
all
Customer types
all
Stages
onboarding, ongoing, investigation, offboarding
Supporting provision
Article 44a, introductory text and points 1-3; Article 44(1)
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: changed, document d80952d9fe69
: unchanged, document c56187ac322d
Conditions
Applies only where the institution is an obliged institution under Article 2(1): banking/financial institutions (point 1), cooperative savings and credit unions and their national association (point 2), payment/e-money entities (point 3), investment/fund entities (points 4, 5 and 7), or the specified virtual-currency exchange, intermediation or account services (point 12). Product labels alone do not establish statutory scope; crypto does not mean every MiCA activity.
The transaction conducted by an individual, legal person or organisational unit without legal personality must be connected with a high-risk third country identified by the European Commission. The connection is not limited to the customer's residence or registered office. A current list is not embedded here.
Evidence diagnostics
Record ID
pl-high-risk-country-countermeasure
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
risk
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
No exceptions are recorded. This does not establish that none apply.
legislation / Review pending
Provide AML privacy information and protect personal data
What this requires
Before the relationship or occasional transaction, explain statutory AML data processing; limit and secure personal data and respect applicable retention duties.
RegCanary explanation
For data collected from the person, give the applicable GDPR Article 13 information, including purposes, legal basis, recipients, retention and relevant rights. Processing necessary for a legal obligation does not depend on consent. Apply purpose limitation, minimisation, accuracy, storage limitation and risk-appropriate security. Erasure is not required to the extent processing remains necessary for a legal obligation or qualifying legal claims; neither exception permits indefinite retention without a continuing basis.
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: changed, document d80952d9fe69
: unchanged, document c56187ac322d
Source check failed
European Parliament and Council / EUR-Lex
Source diagnostics
Lifecycle
Source check failed
Language
pl
Retrieved
11 Sept 2026
Extraction
captured
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
unvalidated
Type
legislation
Version
EUR-Lex consolidated version 4 May 2016, incorporating corrigenda; Articles 5, 6, 13, 17 and 32 inspected
Official Polish PDF obtained by standard Publications Office CELEX content negotiation (Accept application/pdf; Accept-Language pl), without challenge bypass. Original: data/country-handbook-evidence/pl/eu-gdpr-cellar-pl.pdf. Actual original bytes hashed; PDF language/version matched to the previously inspected Polish text. Canonical EUR-Lex text: https://eur-lex.europa.eu/legal-content/PL/TXT/HTML/?uri=CELEX:02016R0679-20160504. Header 02016R0679 - PL - 04.05.2016 - 000.003, incorporating Polish corrigenda from 2018 and 2021. Informational consolidation; authentic Official Journal acts control. Article 99 application: 25 May 2018.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document 51f7dd566c68
: unchanged, document 51f7dd566c68
: unchanged, document 51f7dd566c68
: unchanged, document 51f7dd566c68
: unchanged, document 51f7dd566c68
Conditions
Applies only where the institution is an obliged institution under Article 2(1): banking/financial institutions (point 1), cooperative savings and credit unions and their national association (point 2), payment/e-money entities (point 3), investment/fund entities (points 4, 5 and 7), or the specified virtual-currency exchange, intermediation or account services (point 12). Product labels alone do not establish statutory scope; crypto does not mean every MiCA activity.
GDPR protects natural persons, including representatives and beneficial owners associated with company or trust customers; it does not turn all information about a legal person into personal data.
Security controls must be proportionate to processing risks. Encryption and pseudonymisation are statutory examples where appropriate, not universal mandatory CDD documents.
Exceptions
Article 34(4) permits copies of identity documents; it does not require every customer to provide a scanned identity document.
GDPR Article 13(4) qualifies information already held by the person. Confidentiality and any specific statutory restrictions still require a separate assessment; there is no blanket AML exemption from data protection.
Evidence diagnostics
Record ID
pl-aml-privacy
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
requirements
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation
Maintain sanctions controls for funds and crypto transfers
What this requires
In-scope payment and crypto-asset service providers must maintain internal policies, procedures and controls to implement EU and national restrictive measures.
RegCanary explanation
The transfer regulation imposes a provider-level control duty; it does not replace the conditions, prohibitions or permissions in the applicable sanctions regime. Determine which measures apply to the transfer and relevant parties. This handbook's selected asset-freezing entries do not exhaust all EU regimes.
Official Polish PDF obtained by standard Publications Office CELEX content negotiation (Accept application/pdf; Accept-Language pl), without challenge bypass. Original: data/country-handbook-evidence/pl/eu-tfr-cellar-pl.pdf. Actual original bytes hashed; PDF language/version matched to the previously inspected Polish text. Canonical EUR-Lex text: https://eur-lex.europa.eu/legal-content/PL/TXT/HTML/?uri=CELEX:32023R1113. Polish OJ L 150, 9 June 2023. Article 40 application: 30 December 2024. Future repeal of Article 38 on 10 July 2027 does not repeal the mapped direct transfer duties; completed national transposition is not inferred.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document 4d78dc45d6fb
: unchanged, document 4d78dc45d6fb
: unchanged, document 4d78dc45d6fb
: unchanged, document 4d78dc45d6fb
: unchanged, document 4d78dc45d6fb
Conditions
Applies only to an in-scope transfer under Regulation (EU) 2023/1113 Articles 1-3 and to the stated provider role. A banking, investment, payment or fintech label alone does not establish that role. Funds-transfer duties apply to EU-established payment service providers; crypto-transfer duties apply where the relevant crypto-asset service provider has its registered office in the EU.
Exceptions
Article 2 excludes the specified payment services, qualifying goods/services-only card or e-money payments, pure technical support, own-account provider transfers, own-account cash withdrawals, specified public-authority payments and cheque-image transfers. Consumer person-to-person card/e-money transfers are not covered by the goods/services exclusion. No Polish exercise of the optional Article 2(5) domestic exemption is assumed.
Article 2 excludes own-account transfers where both parties are crypto-asset service providers, and person-to-person transfers without a crypto-asset service provider. E-money tokens are treated as crypto-assets, subject to the conditional goods/services payment exclusion in Article 2(3). A self-hosted address does not itself exempt a transfer involving a provider.
Evidence diagnostics
Record ID
pl-transfer-sanctions-controls
Lifecycle
Verified
Scenario applicability
needs judgement
Topic
monitoring
Status when reviewed
current
Review status
source checked
Effective from
30 Dec 2024
Effective to
Not recorded
Status basis
The requirement is marked source-checked.
A supporting source is not confirmed as current.
Structured applicability has not been established for this scenario. The requirement remains readable, but this is not a firm-specific applicability conclusion.
legislation
Protect transfer information and respond to competent authorities
What this requires
Use transfer personal data only for AML/CTF purposes, give new customers the required privacy information and comply with the transfer-record retention provisions.
RegCanary explanation
Respond fully and without delay, under the applicable national procedure, only to requests about this regulation from the establishment state's competent AML/CTF authorities. Give the prescribed plain, accessible privacy information before a new relationship or occasional transaction. Commercial use of data processed under this regulation is prohibited. Payer/payee providers retain Articles 4-7 information, and originator/beneficiary providers retain Articles 14-16 information, for five years; delete personal data afterwards unless applicable national law authorises or requires further retention, which may not exceed an additional five years.
Official Polish PDF obtained by standard Publications Office CELEX content negotiation (Accept application/pdf; Accept-Language pl), without challenge bypass. Original: data/country-handbook-evidence/pl/eu-tfr-cellar-pl.pdf. Actual original bytes hashed; PDF language/version matched to the previously inspected Polish text. Canonical EUR-Lex text: https://eur-lex.europa.eu/legal-content/PL/TXT/HTML/?uri=CELEX:32023R1113. Polish OJ L 150, 9 June 2023. Article 40 application: 30 December 2024. Future repeal of Article 38 on 10 July 2027 does not repeal the mapped direct transfer duties; completed national transposition is not inferred.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document 4d78dc45d6fb
: unchanged, document 4d78dc45d6fb
: unchanged, document 4d78dc45d6fb
: unchanged, document 4d78dc45d6fb
: unchanged, document 4d78dc45d6fb
Conditions
Applies only to an in-scope transfer under Regulation (EU) 2023/1113 Articles 1-3 and to the stated provider role. A banking, investment, payment or fintech label alone does not establish that role. Funds-transfer duties apply to EU-established payment service providers; crypto-transfer duties apply where the relevant crypto-asset service provider has its registered office in the EU.
The Article 26(1) five-year duty names payer/payee and originator/beneficiary providers. Do not assign that paragraph indiscriminately to every intermediary. Article 19 separately requires intermediary crypto records.
Article 26 does not state a relationship-end timing anchor in the inspected text. Do not substitute Poland's Article 49 trigger or create an automatic ten-year retention period; reconcile records subject to both instruments.
Exceptions
Article 2 excludes the specified payment services, qualifying goods/services-only card or e-money payments, pure technical support, own-account provider transfers, own-account cash withdrawals, specified public-authority payments and cheque-image transfers. Consumer person-to-person card/e-money transfers are not covered by the goods/services exclusion. No Polish exercise of the optional Article 2(5) domestic exemption is assumed.
Article 2 excludes own-account transfers where both parties are crypto-asset service providers, and person-to-person transfers without a crypto-asset service provider. E-money tokens are treated as crypto-assets, subject to the conditional goods/services payment exclusion in Article 2(3). A self-hosted address does not itself exempt a transfer involving a provider.
The historical Article 26(3) provision about proceedings pending on 25 June 2015 is not a general present-day retention extension.
Evidence diagnostics
Record ID
pl-transfer-information-protection
Lifecycle
Verified
Scenario applicability
needs judgement
Topic
monitoring
Status when reviewed
current
Review status
source checked
Effective from
30 Dec 2024
Effective to
Not recorded
Status basis
The requirement is marked source-checked.
A supporting source is not confirmed as current.
Structured applicability has not been established for this scenario. The requirement remains readable, but this is not a firm-specific applicability conclusion.
legislation / Review pending
Apply the specific basic-account access and refusal rules
What this requires
For qualifying basic-account applications, distinguish mandatory refusal grounds from discretionary grounds and give reasons unless disclosure is legally restricted.
RegCanary explanation
Decide without delay and no later than ten working days after a complete application; the credit-union clock starts when membership eligibility is confirmed. Mandatory refusal covers justified ML/TF crime suspicion, failure of the credit-union membership criteria, and credible information of the consumer's involvement in crime using an account or criminal origin of intended funds. The statutory optional grounds are different: another qualifying account subject to the closure-information exception; matching sanctions/KNF warning-list identity data; no valid identity document; previous serious contractual breach; failure to sign within the statutory arrangement; no lawful presence in a Member State; or no Polish residential/correspondence address. Explain refusal promptly and without charge unless disclosure would threaten national security/public order or breach law, including AML confidentiality. An ML/TF-ground refusal also requires the appropriate AML measures.
Original: data/country-handbook-evidence/pl/D20260623Lj-delivery.pdf (242 pages). Articles 4(2)(1)-(3), (9), 59ia-59ic and 59if-59ig inspected, including native pages 93-100. Underlying and consolidation metadata captured. Future amendments 875 (Article 12) and 1074 (Article 5) were checked: they concern provider registration/fees, not the mapped basic-account provisions. Their 2027 changes are not current duties. Consolidation/publication is not used as the commencement date.
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: changed, document d80952d9fe69
: unchanged, document c56187ac322d
Conditions
Only basic payment accounts offered to consumers by the Article 4(2)(1)-(3) banks/credit institutions/branches and point 9 credit unions that offer consumer payment accounts; the national credit-union association is excluded. The credit-union obligation concerns its members. It is not a general duty of every payment/e-money firm or a company/trust account rule.
The account is intended for a consumer without another qualifying Polish-currency account offered through the specified providers' Polish activity. Additional-service contracts or a declared minimum incoming amount cannot be required, without prejudice to credit-union membership obligations.
For an accepted electronic application, the law permits setting at least ten working days to sign in a branch or entering the contract remotely. A generic ten-day calendar deadline is incorrect.
Exceptions
The optional grounds do not remove independent mandatory AML duties. A high-risk score alone is not substituted for a statutory refusal ground.
A sanctions-list identity-data match is a stated discretionary basic-account ground; this is not a determination that a particular customer is designated or that a live screening result is correct.
Evidence diagnostics
Record ID
pl-basic-account-refusal
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
verification
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
legislation / Review pending
Apply the EU measures for overseas legal obstacles
What this requires
In-scope credit and financial institutions must assess third-country group risks and apply the particular countermeasures required by the identified legal obstacle.
RegCanary explanation
For each relevant third country, document and update the risk assessment, reflect it in group procedures, obtain group senior-management approval and provide effective targeted training. When local law blocks risk assessment, intra-group data use, suspicious-report information, supervisory data transfer or record retention, notify the home competent authority without undue delay and within the applicable 28-day period from identifying the third country and explain the obstacle. Apply the specific branch of Articles 3-7, not an interchangeable generic list of measures.
Official Polish PDF obtained by standard Publications Office CELEX content negotiation (Accept application/pdf; Accept-Language pl), without challenge bypass. Original: data/country-handbook-evidence/pl/eu-group-cellar-pl.pdf. Actual original bytes hashed; PDF language/version matched to the previously inspected Polish text. Canonical EUR-Lex text: https://eur-lex.europa.eu/legal-content/PL/TXT/HTML/?uri=CELEX:32019R0758. Polish OJ L 125, 14 May 2019; operative Articles 1-9 inspected. Article 9 application: 3 September 2019. Credit/financial-institution scope is not every national obliged institution.
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: changed, document d80952d9fe69
: unchanged, document c56187ac322d
Conditions
Applies to credit and financial institutions with branches or majority-owned subsidiaries in third countries under the EU regulation's scope; it does not apply to every Polish obliged institution. Broader crypto institution classification is not inferred from a virtual-currency registration.
For customer/beneficial-owner risk-information obstacles, Article 3 requires assessing lawful consent and obtaining it where lawful; if unavailable, Article 8(c) reviews plus at least one of (a), (b), (d), (e), (f). If risk cannot be managed, end the relationships, do not execute occasional transactions and close some or all affected operations.
For intra-group customer-data obstacles, Article 4 requires the lawful-consent assessment/route; if unavailable, at least Article 8(a) low-risk product limitation or (c) reviews, with further (a)-(c) measures where risk requires. Unmanageable risk requires closing some or all affected operations.
For suspicious-report information obstacles, Article 5 requires suitable information to group senior management and at least one Article 8(a)-(c) or (g)-(i) measure; inability to manage risk requires operational closure. Aggregate report counts and circumstances are examples of suitable management information, not universal customer fields.
For blocked supervisory access, Article 6 requires thorough reviews, proportionate on-site/independent audits, findings on request, and regular senior-management information including high-risk customer and suspicious-transaction counts with aggregate reasons; provide that information to the home authority on request.
For record-retention obstacles, Article 7 requires the lawful-consent assessment/route and, if unavailable, at least one Article 8(a)-(c) or (j) measure. Determine and demonstrate a risk-proportionate scope. Article 7 does not repeat the automatic operational-closure fallback of Articles 3-5.
Articles 3(1)(a) and 6(a) expressly say 28 calendar days; Articles 4(1)(a), 5(1)(a) and 7(1)(a) say 28 days. These clocks arise under the EU regulation, not by inserting a numerical deadline into national Article 51.
Exceptions
Consent is a possible lawful means of overcoming the particular third-country barrier, not a replacement for the general legal basis for mandatory AML processing.
The Article 8 measures have prescribed combinations: limiting products, disallowing reliance, reviews/audits, senior approval, source/use of funds, enhanced monitoring, legally permissible suspicion information, monitoring persons reported elsewhere in the group, effective reporting systems, and risk/CDD retention as long as lawful. Do not treat all ten as simultaneously mandatory in every case.
Evidence diagnostics
Record ID
pl-group-obstacle-countermeasures
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
requirements
Baseline review status
source checked
Review status
needs review
Effective from
3 Sept 2019
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
guidance / Review pending
Report domestic freezes through the published KAS route
What this requires
Follow KAS guidance to report a domestic financial-asset freeze to the Head of KAS, identifying the asset, value and owner.
RegCanary explanation
KAS Question 11 expressly includes freezes under Article 1 of the Polish sanctions Act. Report the financial asset's kind, value and owner. For an individual owner, provide nationality, name, residential address and PESEL or NIP if assigned, or passport number, insofar as possible. For a non-natural owner, provide its name, NIP or relevant register number and address. The current KAS reporting-address page includes the domestic Act and supplies the Head of KAS reporting channels. This is competent-authority guidance, not incorporation of the whole EU Article 8 into domestic law.
Applicability
Business lines
all
Customer types
all
Stages
onboarding, ongoing, investigation, offboarding
Supporting provision
KAS sanctions FAQ Question 11 (PDF pages 3-4); KAS heading 'Adresy do przekazywania informacji o dokonanych mrozeniach zwiazanych z wojna w Ukrainie'; National Sanctions Act Articles 1(2), 6(1)(2)
Source check failed
National Revenue Administration (KAS)
Source diagnostics
Lifecycle
Source check failed
Language
pl
Retrieved
11 Sept 2026
Extraction
captured
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
unvalidated
Type
sanctions
Version
Undated Polish FAQ currently linked from KAS sanctions page; Question 11, PDF pages 3-4
Original: data/country-handbook-evidence/pl/kas-sanctions-faq-core.pdf. Question 11 checked with current KAS reporting-address heading and national Act Articles 1(2), 6(1)(2). Explicitly includes national Act freezes and conditional owner particulars, but no numerical deadline. Unrelated trade or Russian-counterparty answers are not mapped as current advice on every regime.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document 3b6019003d71
: unchanged, document 3b6019003d71
: unchanged, document 3b6019003d71
: unchanged, document 3b6019003d71
: unchanged, document 3b6019003d71
Source changed
Ministerstwo Finansow / Krajowa Administracja Skarbowa
Source diagnostics
Lifecycle
Source changed
Language
pl
Retrieved
10 Sept 2026
Extraction
captured
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
requires-revalidation
Type
sanctions
Version
Live Polish operational guidance at retrieval; no publication-based commencement assigned
Headings on reporting frozen assets, delegated Wroclaw authority for releases, and releasing frozen funds inspected. Distinguishes Head of KAS competence from the published operational receiving office and delegated release authority. Current page routes relevant reports and applications to Dolnoslaski Urzad Celno-Skarbowy we Wroclawiu. Article 5r trade-related reporting and other regimes are not mapped from this page. Original: data/country-handbook-evidence/pl/kas-sanctions-20260911.html.
Status basis
A source change or revalidation is awaiting review.
Articles 1-6 inspected, physical pp.2-4. Mapping is bounded to the domestic-list measures corresponding to Regulation 269/2014, decision scope, authority and selected derogations. Article 1(2) excludes Regulation Article 8 whereas Article 6(1)(2) mentions it in penalties; no universal domestic two-week deadline is inferred. Underlying-act metadata identifies 2025/172 as latest amendment at retrieval. No live designation decisions reviewed. Original: data/country-handbook-evidence/pl/D20250514L-20260911.pdf.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document c660951fad2a
: unchanged, document c660951fad2a
: unchanged, document c660951fad2a
: unchanged, document c660951fad2a
: unchanged, document c660951fad2a
Conditions
Applies where a domestic decision requires the relevant freeze under Polish law; not limited to national AML obliged institutions.
National Article 6(1)(2) penalises failure to provide the referenced information immediately. Article 1(2) nevertheless expressly excludes EU Article 8. Read the national wording with KAS reporting guidance; a domestic-only listing is not an EU Annex I designation.
Exceptions
Neither KAS Question 11 nor the national text supplies a universal domestic two-week grace period. The EU Article 8 clock is mapped separately for cases within that regulation; do not postpone domestic reporting by importing that period.
The owner's particulars are qualified as stated, not a universal customer-onboarding dataset. This does not resolve every sanctions regime or the drafting cross-reference in contested proceedings.
Evidence diagnostics
Record ID
pl-national-freeze-report-guidance
Lifecycle
Needs review
Scenario applicability
Not recorded
Topic
monitoring
Baseline review status
source checked
Review status
needs review
Effective from
Not recorded
Effective to
Not recorded
Status basis
The requirement is marked as needing review.
guidance
Assess and oversee remote-onboarding solutions
What this requires
Establish risk-based remote-onboarding policies, management oversight and a documented assessment before implementing a new solution.
RegCanary explanation
Define customer and service eligibility, automated and staff tasks, training and completion of initial CDD before the first transaction. Assess data reliability, risk impact, mitigation, fraud and security exposure, and end-to-end functioning before implementation. Monitor the solution and remedy weaknesses, reviewing affected relationships and considering further CDD, permissible restrictions, termination, FIU reporting or reclassification according to the findings. These are institutional controls described by the handbook, not customer-clearance or execution functions.
Original: data/country-handbook-evidence/pl/eba-remote-pl.pdf. Polish paragraphs 1-7, section 3 and paragraphs 9-54 inspected. EBA product page identifies guidance as in force. Article 16 guidance, not directly applicable legislation. Compliance workbook updated 28 April 2025, Table row 41, records KNF 'Intends to comply' by 2 October 2023, notified 29 May 2023; not relabelled confirmed compliance. Workbook: data/country-handbook-evidence/pl/eba-remote-compliance.xlsx, SHA-256 f319a323cdab5fd35ddbb65de03f369e0c74152c92381b07f915aada310b4b86, retrieved 2026-09-11T07:59:32.993Z.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document fb448b25e067
: unchanged, document fb448b25e067
: unchanged, document fb448b25e067
: unchanged, document fb448b25e067
: unchanged, document fb448b25e067
Conditions
Applies to remote onboarding by credit and financial institutions addressed in paragraphs 5-7 and the referenced EU financial-institution definition. A business selection alone does not establish that status.
EBA Article 16 guidance requires every effort to comply; it is not additional Polish statutory identity fields. EBA's published table records KNF's intention to comply by 2 October 2023, not a later confirmed-compliance notification.
A standalone virtual-currency business is not included merely because it is a national AML obliged institution. Its binding national verification and risk duties remain applicable.
Exceptions
Paragraph 15 treats specified notified substantial/high-assurance electronic identification schemes or appropriate qualified trust services as satisfying only paragraph 14(a), (d) and (e), not the whole risk assessment.
Remedial options depend on the findings and applicable law; a technical failure is not automatically a suspicious activity report.
Evidence diagnostics
Record ID
pl-remote-onboarding-governance
Lifecycle
Verified
Scenario applicability
needs judgement
Topic
requirements
Status when reviewed
current
Review status
source checked
Effective from
2 Oct 2023
Effective to
Not recorded
Status basis
The requirement is marked source-checked.
A supporting source is not confirmed as current.
Structured applicability has not been established for this scenario. The requirement remains readable, but this is not a firm-specific applicability conclusion.
guidance
Maintain reliable remote identity and representative checks
What this requires
Use reliable remote evidence for identity and authority to act, and stop an unreliable remote process rather than accepting incomplete verification.
RegCanary explanation
EBA guidance covers readable, current evidence, document authenticity and integrity, identity matching and secure timestamped records. For legal entities, collect relevant entity, beneficial-owner and representative-authority evidence and identify the person acting for the entity. Do not continue identification through technical faults or unexpected disconnections. Where evidence quality creates uncertainty, interrupt and restart or redirect to face-to-face verification. Unattended solutions call for contemporaneous images and liveness checks; attended solutions call for suitable audiovisual quality and trained staff.
Original: data/country-handbook-evidence/pl/eba-remote-pl.pdf. Polish paragraphs 1-7, section 3 and paragraphs 9-54 inspected. EBA product page identifies guidance as in force. Article 16 guidance, not directly applicable legislation. Compliance workbook updated 28 April 2025, Table row 41, records KNF 'Intends to comply' by 2 October 2023, notified 29 May 2023; not relabelled confirmed compliance. Workbook: data/country-handbook-evidence/pl/eba-remote-compliance.xlsx, SHA-256 f319a323cdab5fd35ddbb65de03f369e0c74152c92381b07f915aada310b4b86, retrieved 2026-09-11T07:59:32.993Z.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document fb448b25e067
: unchanged, document fb448b25e067
: unchanged, document fb448b25e067
: unchanged, document fb448b25e067
: unchanged, document fb448b25e067
Conditions
Applies to remote onboarding by credit and financial institutions addressed in paragraphs 5-7 and the referenced EU financial-institution definition. A business selection alone does not establish that status.
EBA Article 16 guidance requires every effort to comply; it is not additional Polish statutory identity fields. EBA's published table records KNF's intention to comply by 2 October 2023, not a later confirmed-compliance notification.
A standalone virtual-currency business is not included merely because it is a national AML obliged institution. Its binding national verification and risk duties remain applicable.
Exceptions
Paragraphs 25 and 45 recognise specified notified substantial/high-assurance electronic identification schemes or appropriate qualified trust services as satisfying the identified criteria; do not impose universal video or liveness capture regardless of method.
Paragraph 44's additional controls are risk-proportionate alternatives or similar measures, not a mandatory first-payment, biometric and telephone checklist for every customer.
Records remain subject to purpose, necessity, security and retention rules; not every possible image or biometric identifier must be collected.
Evidence diagnostics
Record ID
pl-remote-onboarding-verification
Lifecycle
Verified
Scenario applicability
needs judgement
Topic
verification
Status when reviewed
current
Review status
source checked
Effective from
2 Oct 2023
Effective to
Not recorded
Status basis
The requirement is marked source-checked.
A supporting source is not confirmed as current.
Structured applicability has not been established for this scenario. The requirement remains readable, but this is not a firm-specific applicability conclusion.
Act of 1 March 2018 on counteracting money laundering and financing of terrorism: updated Polish text
Downloaded 134-page Polish updated text (tekst ujednolicony), not a new enactment. Includes bracketed future text; status current refers only to operative provisions used here. Article 15 of Dz.U. 2026 poz. 875 changes Articles 129f/129h from 2027-01-01, outside these requirement records. ELI metadata for 2025/644 lists only 1669 as a subsequent amendment although the actual PDF also includes 875. Original: data/country-handbook-evidence/pl/D20250644Lj.pdf. Editorial/publication dates are not requirement commencement dates. The captured ELI record for the underlying 2018 Act (eli-2018-723.json) lists both 1669 and future 875 and no later amendment; its changeDate is 2026-07-28. This is a bounded official-source currency check, not an exhaustive legislative opinion. Entity expansion rechecked Articles 2(1)(2), 2(2)(1) and (24), 34, 36-39 and 58(6) against an identical fresh original captured at 2026-09-10T19:12:10.943Z: data/country-handbook-evidence/pl/D20250644Lj-entity-expansion-20260910.pdf. Fresh underlying-Act metadata is retained as eli-2018-723-entity-expansion-20260910.json; no new amendment was listed. Coverage expansion re-downloaded the identical official PDF at 2026-09-10T20:38:35.799Z and checked Articles 2(1), 27, 33-35, 38, 45, 49-50, 54, 58, 61a, 72-79 and 86-90 as cited. Fresh original: data/country-handbook-evidence/pl/D20250644Lj-coverage-20260910.pdf. Fresh underlying-Act metadata: data/country-handbook-evidence/pl/eli-2018-723-coverage-20260910.json; same amendment list and 2027-01-01 boundary.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: unchanged, document d80952d9fe69
: changed, document d80952d9fe69
: unchanged, document c56187ac322d
Mapped requirements
Act of 17 October 2025 amending homebuyer protection and other acts: AML amendment
Article 6 changes AML Act Article 72(6)(7a) and adds Article 72(7) for notarial real-estate data; Article 9(4) expressly commences Article 6 on 2026-06-30. Other parts have different future commencement dates. Not used to date the existing financial-sector threshold-reporting obligation. Original: data/country-handbook-evidence/pl/D20251669.pdf.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document fbc4541e53b3
: unchanged, document fbc4541e53b3
: unchanged, document fbc4541e53b3
: unchanged, document fbc4541e53b3
: unchanged, document fbc4541e53b3
Mapped requirements
No mapped requirement is available in this selected reading view.
Act of 11 June 2026 simplifying administrative procedures: future AML registration amendment
Articles 15, 19(3) and 22 checked. Changes concern company/trust service-provider registration, not CDD for customers that are companies/trusts. Article 22 commencement formula and ELI entryIntoForce establish 2027-01-01. ELI generic IN_FORCE label must not override that date. No future obligation is presented as current. Original: data/country-handbook-evidence/pl/D20260875.pdf.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document 4fd1512a8df1
: unchanged, document 4fd1512a8df1
: unchanged, document 4fd1512a8df1
: unchanged, document 4fd1512a8df1
: unchanged, document 4fd1512a8df1
Mapped requirements
No mapped requirement is available in this selected reading view.
UKNF position on AML/CFT processes to be regulated in internal procedures
34 physical PDF pages: cover plus printed pages 1-33. Opening scope and printed pages 1 and 3 checked for the guidance record. Applies to obliged institutions supervised by KNF, not automatically to every AML obliged institution. Publication provenance captured from https://www.knf.gov.pl/aktualnosci?articleId=97485&p_id=18 in knf-position-publication.html. Publication is not a statutory effective date. Original: data/country-handbook-evidence/pl/Stanowisko_UKNF_AML_CFT_97484.pdf.
Status basis
The source could not be extracted successfully.
Recent document checks
: changed, document 143e3b7d4cf2
: changed, document ea75e9accff3
: changed, document 143e3b7d4cf2
: unchanged, document ea75e9accff3
: changed, document ea75e9accff3
Mapped requirements
No mapped requirement is available in this selected reading view.
Legislation: English AML/CFT translations and binding-language warning
Source changed
Ministry of Finance
Source diagnostics
Lifecycle
Source changed
Language
en
Retrieved
10 Sept 2026
Extraction
captured
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
requires-revalidation
Type
legislation
Version
Page states last updated 17 April 2025; translation currency not established
Captured HTML expressly states translations are for information only, not all legislation is translated, and only Polish text is binding. No requirement relies on the linked English translation. Original: data/country-handbook-evidence/pl/ministry-legislation-en.html.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: unchanged, document 729c07cc4685
: unchanged, document 729c07cc4685
: unchanged, document 729c07cc4685
: unchanged, document 729c07cc4685
: unchanged, document 729c07cc4685
Mapped requirements
No mapped requirement is available in this selected reading view.
Act of 1 March 2018: Ministry-hosted English DOCX translation
Source check failed
Ministry of Finance
Source diagnostics
Lifecycle
Source check failed
Language
en
Retrieved
Not recorded
Extraction
discovered
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
unvalidated
Type
legislation
Version
Translation version not checked
SHA-256
Not recorded
Source notes
Attachment discovered on the Ministry English legislation page; not downloaded or extracted. Its filename does not establish the amendment cut-off. Not used as legal evidence.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document fd3270293771
: unchanged, document fd3270293771
: unchanged, document fd3270293771
: unchanged, document fd3270293771
: unchanged, document fd3270293771
Mapped requirements
No mapped requirement is available in this selected reading view.
Raportowanie informacji do GIIF: official reporting guidance index
Discovery index, not evidence that every linked notice is current. Lists crypto quarterly reporting notices 67/72, transaction reporting and notarial updates including notice 110. Statutory reporting records below are checked against the Act, not inferred from this index. Original: data/country-handbook-evidence/pl/giif-reporting-index.html.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: unchanged, document ffa6593e9751
: unchanged, document ffa6593e9751
: unchanged, document ffa6593e9751
: unchanged, document ffa6593e9751
: unchanged, document ffa6593e9751
Mapped requirements
No mapped requirement is available in this selected reading view.
Komunikat nr 21: Article 86 notifications during the COVID-19 epidemic
Content checked. Epidemic-era optional request to submit between 11:00 and 14:00 where feasible; explicitly not obligatory where disruptive. Retained as historical context, not a current reporting window or permission to delay immediate reporting. Original: data/country-handbook-evidence/pl/giif-reporting-21.html.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: unchanged, document 872a6a753f72
: unchanged, document 872a6a753f72
: unchanged, document 872a6a753f72
: unchanged, document 872a6a753f72
: unchanged, document 872a6a753f72
Mapped requirements
No mapped requirement is available in this selected reading view.
Krajowa Ocena Ryzyka Prania Pieniędzy oraz Finansowania Terroryzmu: publication index
Latest assessment on this official index at retrieval is 2023. This is a bounded publication check, not proof that no other official update exists. Index identifies main report and Annexes 1-3. Original: data/country-handbook-evidence/pl/giif-nra-index.html. Re-fetched at 2026-09-10T20:38:36.949Z with the identical checksum; the 2023 assessment remains the latest listed. Fresh original: data/country-handbook-evidence/pl/giif-nra-index-coverage.html.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: unchanged, document 68532ee14306
: unchanged, document 68532ee14306
: unchanged, document 68532ee14306
: unchanged, document 68532ee14306
: unchanged, document 68532ee14306
Mapped requirements
Krajowa Ocena Ryzyka Prania Pieniędzy oraz Finansowania Terroryzmu 2023
335-page original retained. Coverage expansion inspected section 7.2.1, including paragraphs 587-588 (printed p.215), 603-604 (p.221), 610-611 (p.223) and 626 (p.225), using local Poppler extraction from the original. Selected banking, payment and virtual-currency vulnerabilities inform bounded implementation examples. Current means latest listed on the re-fetched GIIF NRA index, not current-year data or current law. Historic regulatory descriptions and universal claims about anonymity are not adopted. No numeric sector score has been mapped. Original: data/country-handbook-evidence/pl/giif-nra-2023.pdf.
197-page original retained. Coverage expansion inspected banking Tables 1-2 (pp.2-5), non-bank payment Tables 9-11 (pp.26-29), and virtual-currency Tables 32-34 (pp.83-86), using Poppler directly without modifying the handbook parser. Published examples selected for the three sector mappings have exact table/scenario locators. Not a full annex or all-sector review. NRA examples are not current regulatory-perimeter statements or automatic customer risk classifications. Original: data/country-handbook-evidence/pl/giif-nra-2023-annex-2.pdf.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document c6019b1fb4bf
: unchanged, document c6019b1fb4bf
: unchanged, document c6019b1fb4bf
: unchanged, document c6019b1fb4bf
: unchanged, document c6019b1fb4bf
Mapped requirements
Sankcje Międzynarodowe: Polish competent authorities and national sanctions
Source changed
Ministry of Foreign Affairs (MSZ)
Source diagnostics
Lifecycle
Source changed
Language
pl
Retrieved
10 Sept 2026
Extraction
captured
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
requires-revalidation
Type
sanctions
Version
Live official authority-allocation page captured 2026-09-10
Sections Wdrażanie sankcji w Polsce and Sankcje krajowe checked. Financial sanctions responsibilities include Head of KAS and GIIF for counterterrorism aspects; MSWiA maintains the separate domestic sanctions list. Detailed EU-regime competence attachments and national sanctions law were linked but not reviewed. Original: data/country-handbook-evidence/pl/msz-sanctions-authorities.html.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: unchanged, document 40c0af3fad51
: unchanged, document 40c0af3fad51
: unchanged, document 40c0af3fad51
: unchanged, document 40c0af3fad51
: unchanged, document 40c0af3fad51
Mapped requirements
No mapped requirement is available in this selected reading view.
Index links Article 118 lists, GIIF listing decisions and EU/UN resources. Individual list entries and all live sanctions designations were not downloaded or reconciled. The asset-freeze requirement is supported by Act Articles 117-119, not by the index alone. Original: data/country-handbook-evidence/pl/giif-sanctions-index.html.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: unchanged, document f9acdfe69a74
: unchanged, document f9acdfe69a74
: unchanged, document f9acdfe69a74
: unchanged, document f9acdfe69a74
: unchanged, document f9acdfe69a74
Mapped requirements
No mapped requirement is available in this selected reading view.
Komunikat nr 67: quarterly reporting by virtual-currency obliged institutions
Source changed
Generalny Inspektor Informacji Finansowej (GIIF)
Source diagnostics
Lifecycle
Source changed
Language
pl
Retrieved
10 Sept 2026
Extraction
captured
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
requires-revalidation
Type
reporting
Version
28 September 2023 notice, corrected 16 October 2023
Full public HTML read. Introduces Article 2(1)(12) quarterly reporting, the qualified-signature submission process and an original 18-day recurring period. The correction concerns Q4 2023, not Q4 2024. Later notice 115 points to a secure message whose contents have not been inspected; current deadline and form cannot be confirmed from notice 67 alone. Not used to publish a fixed current deadline. Original: data/country-handbook-evidence/pl/pl-crypto-reporting-67-coverage.html.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: unchanged, document 04842fa3d588
: unchanged, document 04842fa3d588
: unchanged, document 04842fa3d588
: unchanged, document 04842fa3d588
: unchanged, document 04842fa3d588
Mapped requirements
No mapped requirement is available in this selected reading view.
Komunikat nr 72: changed virtual-currency quarterly reporting deadline
Source changed
Generalny Inspektor Informacji Finansowej (GIIF)
Source diagnostics
Lifecycle
Source changed
Language
pl
Retrieved
10 Sept 2026
Extraction
captured
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
requires-revalidation
Type
reporting
Version
4 January 2024 notice; Q4 2023 submission window only
Full public HTML read. Changes only the Q4 2023 filing window to 8-22 January 2024; expressly leaves other quarterly dates unchanged at that time. Not a recurring 22-day deadline and not evidence that later instructions made no changes. Original: data/country-handbook-evidence/pl/pl-crypto-reporting-72-coverage.html.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: unchanged, document 2d857d82d0a7
: unchanged, document 2d857d82d0a7
: unchanged, document 2d857d82d0a7
: unchanged, document 2d857d82d0a7
: unchanged, document 2d857d82d0a7
Mapped requirements
No mapped requirement is available in this selected reading view.
GIIF notice 37: recording and resolving CRBR beneficial-ownership discrepancies
Full substantive HTML read and statutory basis cross-checked against the freshly captured operative Act. Particular attention to genuine versus apparent differences, missing filings, supporting reasons and documents, and failure to complete CDD. Examples are not mandatory document checklists. Original: data/country-handbook-evidence/pl/giif-crbr-37-coverage.html.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: unchanged, document c3ad9551d7ad
: unchanged, document c3ad9551d7ad
: unchanged, document c3ad9551d7ad
: unchanged, document c3ad9551d7ad
: unchanged, document c3ad9551d7ad
Mapped requirements
No mapped requirement is available in this selected reading view.
GIIF notice 53: foreign transfers routed through a domestic intermediary
Full substantive HTML read; only the recipient-provider Article 72(2) reporting clarification is adopted, checked against current Polish Article 72. The notice's references to Regulation 2015/847 are historical citations, not a confirmation that that EU Regulation remains applicable. Its linked technical materials and the replacement EU transfer regime are not validated here. Original: data/country-handbook-evidence/pl/giif-reporting-53-coverage.html.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: unchanged, document dde88f84d51b
: unchanged, document dde88f84d51b
: unchanged, document dde88f84d51b
: unchanged, document dde88f84d51b
: unchanged, document dde88f84d51b
Mapped requirements
GIIF quarterly statistics: official public FAQ index
Lists the financial-institution FAQ dated 13 October 2025 and virtual-currency FAQ dated 20 May 2024. Publication provenance only, not a reporting demand on every financial firm. Original: data/country-handbook-evidence/pl/giif-quarterly-index-coverage.html.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: unchanged, document ccd783208e5e
: unchanged, document ccd783208e5e
: unchanged, document ccd783208e5e
: unchanged, document ccd783208e5e
: unchanged, document ccd783208e5e
Mapped requirements
No mapped requirement is available in this selected reading view.
GIIF notice 115: secure message on virtual-currency quarterly reporting
Source changed
Generalny Inspektor Informacji Finansowej (GIIF)
Source diagnostics
Lifecycle
Source changed
Language
pl
Retrieved
10 Sept 2026
Extraction
captured
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
requires-revalidation
Type
reporting
Version
Live public notice captured 10 September 2026; publication date not stated in inspected content
Sole substantive paragraph read. Directs Article 2(1)(12) institutions urgently to a message on GIIF's secure portal. Public direction is current evidence; message contents, current deadlines, any changed form and individual delivery are not verified. No authentication or submission attempted. Original: data/country-handbook-evidence/pl/giif-crypto-115-coverage.html.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: unchanged, document 132bdaf8dc19
: unchanged, document 132bdaf8dc19
: unchanged, document 132bdaf8dc19
: unchanged, document 132bdaf8dc19
: unchanged, document 132bdaf8dc19
Mapped requirements
No mapped requirement is available in this selected reading view.
GIIF FAQ: quarterly statistics for financial institutions
Source check failed
Generalny Inspektor Informacji Finansowej (GIIF)
Source diagnostics
Lifecycle
Source check failed
Language
pl
Retrieved
10 Sept 2026
Extraction
captured
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
unvalidated
Type
reporting
Version
13 October 2025 version as labelled on the official index
Six-page Polish PDF extracted. Selected substantive Questions 3, 9, 10 and 15 checked for distinct-client counts, analysis outcome neutrality, zero explanations, independent KNF returns and same-quarter customer departures. Other examples and technical instructions are not generalised. The FAQ alone does not establish every addressee or current deadline. Original: data/country-handbook-evidence/pl/giif-quarterly-financial-faq-20251013.pdf.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document c3b29df3b1cd
: unchanged, document c3b29df3b1cd
: unchanged, document c3b29df3b1cd
: unchanged, document c3b29df3b1cd
: unchanged, document c3b29df3b1cd
Mapped requirements
GIIF FAQ: quarterly statistics for virtual-currency institutions
Source check failed
Generalny Inspektor Informacji Finansowej (GIIF)
Source diagnostics
Lifecycle
Source check failed
Language
pl
Retrieved
10 Sept 2026
Extraction
captured
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
unvalidated
Type
reporting
Version
20 May 2024 version as labelled on the official index
Six-page Polish PDF extracted. Selected Questions 1, 3 and 4 checked for reporting-period versus quarter-end counts, civil-law partnership submission, and customers without transactions. Use only with matching current reporting instructions; notice 115 points to a later private message not inspected here. Detailed form fields and technical operation are not verified. Original: data/country-handbook-evidence/pl/giif-quarterly-crypto-faq-20240520.pdf.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document 564fa6a01df1
: unchanged, document 564fa6a01df1
: unchanged, document 564fa6a01df1
: unchanged, document 564fa6a01df1
: unchanged, document 564fa6a01df1
Mapped requirements
No mapped requirement is available in this selected reading view.
Ustawa z dnia 29 sierpnia 1997 r. - Prawo bankowe
Source check failed
Sejm RP
Source diagnostics
Lifecycle
Source check failed
Language
pl
Retrieved
10 Sept 2026
Extraction
captured
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
requires-revalidation
Type
legislation
Version
Dz.U. 2026 poz. 38; updated Polish text dated 20 July 2026
Articles 41, 48k(2), 106 and 106a(1)-(9), pp.85, 100-101, 196-198 checked. The updated document also contains future amendments; no future bracket was used for these duties. Underlying-act metadata and amendment 846 Articles 7 and 16 inspected; that amendment changes disclosure provisions, not these reporting/hold rules. Commencement histories are not inferred from consolidation dates. Original: data/country-handbook-evidence/pl/D20260038Lj-20260911.pdf.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document 290405bcc096
: unchanged, document 290405bcc096
: unchanged, document 290405bcc096
: changed, document 290405bcc096
: unchanged, document bd3a91bb37d1
Mapped requirements
Ustawa z dnia 5 listopada 2009 r. o spoldzielczych kasach oszczednosciowo-kredytowych
Source check failed
Sejm RP
Source diagnostics
Lifecycle
Source check failed
Language
pl
Retrieved
10 Sept 2026
Extraction
captured
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
requires-revalidation
Type
legislation
Version
Dz.U. 2026 poz. 595; updated Polish text dated 20 July 2026
Articles 10, 15 and 16(1)-(10), pp.19, 25-27 checked in Polish. Article 16 distinguishes reporting by a credit union or the national association from account blocking by a credit union. Future amendments elsewhere in the PDF are not current duties; amendment 846 changes Article 9f, not Article 16. Original: data/country-handbook-evidence/pl/D20260595Lj-20260911.pdf.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document dba9c8c81c05
: unchanged, document dba9c8c81c05
: unchanged, document dba9c8c81c05
: changed, document dba9c8c81c05
: unchanged, document 413d52d3f779
Mapped requirements
Ustawa z dnia 13 kwietnia 2022 r. o szczegolnych rozwiazaniach w zakresie przeciwdzialania wspieraniu agresji na Ukraine oraz sluzacych ochronie bezpieczenstwa narodowego
Articles 1-6 inspected, physical pp.2-4. Mapping is bounded to the domestic-list measures corresponding to Regulation 269/2014, decision scope, authority and selected derogations. Article 1(2) excludes Regulation Article 8 whereas Article 6(1)(2) mentions it in penalties; no universal domestic two-week deadline is inferred. Underlying-act metadata identifies 2025/172 as latest amendment at retrieval. No live designation decisions reviewed. Original: data/country-handbook-evidence/pl/D20250514L-20260911.pdf.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document c660951fad2a
: unchanged, document c660951fad2a
: unchanged, document c660951fad2a
: unchanged, document c660951fad2a
: unchanged, document c660951fad2a
Mapped requirements
Rozporzadzenie Rady (UE) nr 269/2014 - Polish consolidated text
Polish Articles 1(c)-(j), 2, 2a, 4, 7, 8, 9 and 17 inspected. EUR-Lex current-version record corroborates 7 August 2026. Consolidation is informational; authentic Official Journal acts control. Article 1(i)-(j) now contains binding ownership/control definitions, not merely guidance. Annex I is captured but individual designations are not reconciled. No claim to other EU sanctions regimes. Original: data/country-handbook-evidence/pl/eu-269-20260807-pl.html.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: changed, document c7ec117d2d90
: changed, document efc6e9b6dbb4
: changed, document 1e643c838633
: changed, document 66fb6903df41
: changed, document c6e07bfa78f4
Mapped requirements
No mapped requirement is available in this selected reading view.
Unijne najlepsze praktyki w zakresie skutecznego wprowadzania w zycie srodkow ograniczajacych
Source check failed
Council of the European Union
Source diagnostics
Lifecycle
Source check failed
Language
pl
Retrieved
10 Sept 2026
Extraction
captured
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
unvalidated
Type
guidance
Version
Council document 11623/24, 3 July 2024, Polish version
Section VIII, paragraphs 62-70, pp.23-27 inspected, including aggregated ownership and illustrative control indicators. Non-exhaustive guidance, not authority to override the current Regulation or case law. Used only as supplementary assessment guidance beside current Regulation 269/2014 Article 1(i)-(j); not a complete contemporary case-law review. Original: data/country-handbook-evidence/pl/council-11623-2024-pl.pdf.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document 0cd88a53facb
: unchanged, document 0cd88a53facb
: unchanged, document 0cd88a53facb
: unchanged, document 0cd88a53facb
: unchanged, document 0cd88a53facb
Mapped requirements
No mapped requirement is available in this selected reading view.
Sankcje w zwiazku z agresja na Ukraine - KAS
Source changed
Ministerstwo Finansow / Krajowa Administracja Skarbowa
Source diagnostics
Lifecycle
Source changed
Language
pl
Retrieved
10 Sept 2026
Extraction
captured
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
requires-revalidation
Type
sanctions
Version
Live Polish operational guidance at retrieval; no publication-based commencement assigned
Headings on reporting frozen assets, delegated Wroclaw authority for releases, and releasing frozen funds inspected. Distinguishes Head of KAS competence from the published operational receiving office and delegated release authority. Current page routes relevant reports and applications to Dolnoslaski Urzad Celno-Skarbowy we Wroclawiu. Article 5r trade-related reporting and other regimes are not mapped from this page. Original: data/country-handbook-evidence/pl/kas-sanctions-20260911.html.
Status basis
A source change or revalidation is awaiting review.
Original captured at data/country-handbook-evidence/pl/D20250502-pep.pdf; 8 pages, Poppler extraction inspected. Sections 1-2, including selected positions in points 1-30 and 38-45, checked against the statutory PEP definition. Underlying-act metadata at https://api.sejm.gov.pl/eli/acts/DU/2021/1381 identifies this as the latest consolidation at inspection; metadata original retained as pep-underlying-delivery.json. The older 2023 consolidation is not used as current proof. This is a list of domestic functions, not a current register of office-holders. Publication is not treated as a new commencement date.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document 58af8da27d2b
: unchanged, document 58af8da27d2b
: unchanged, document 58af8da27d2b
: unchanged, document 58af8da27d2b
: unchanged, document 58af8da27d2b
Mapped requirements
Regulation (EU) 2023/1113 on information accompanying transfers of funds and certain crypto-assets
Source check failed
European Parliament and Council / EUR-Lex
Source diagnostics
Lifecycle
Source check failed
Language
pl
Retrieved
11 Sept 2026
Extraction
captured
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
unvalidated
Type
legislation
Version
Polish Official Journal text, OJ L 150, 9 June 2023; Articles 1-26 and 40 inspected
Official Polish PDF obtained by standard Publications Office CELEX content negotiation (Accept application/pdf; Accept-Language pl), without challenge bypass. Original: data/country-handbook-evidence/pl/eu-tfr-cellar-pl.pdf. Actual original bytes hashed; PDF language/version matched to the previously inspected Polish text. Canonical EUR-Lex text: https://eur-lex.europa.eu/legal-content/PL/TXT/HTML/?uri=CELEX:32023R1113. Polish OJ L 150, 9 June 2023. Article 40 application: 30 December 2024. Future repeal of Article 38 on 10 July 2027 does not repeal the mapped direct transfer duties; completed national transposition is not inferred.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document 4d78dc45d6fb
: unchanged, document 4d78dc45d6fb
: unchanged, document 4d78dc45d6fb
: unchanged, document 4d78dc45d6fb
: unchanged, document 4d78dc45d6fb
Mapped requirements
General Data Protection Regulation: current Polish consolidated text
Source check failed
European Parliament and Council / EUR-Lex
Source diagnostics
Lifecycle
Source check failed
Language
pl
Retrieved
11 Sept 2026
Extraction
captured
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
unvalidated
Type
legislation
Version
EUR-Lex consolidated version 4 May 2016, incorporating corrigenda; Articles 5, 6, 13, 17 and 32 inspected
Official Polish PDF obtained by standard Publications Office CELEX content negotiation (Accept application/pdf; Accept-Language pl), without challenge bypass. Original: data/country-handbook-evidence/pl/eu-gdpr-cellar-pl.pdf. Actual original bytes hashed; PDF language/version matched to the previously inspected Polish text. Canonical EUR-Lex text: https://eur-lex.europa.eu/legal-content/PL/TXT/HTML/?uri=CELEX:02016R0679-20160504. Header 02016R0679 - PL - 04.05.2016 - 000.003, incorporating Polish corrigenda from 2018 and 2021. Informational consolidation; authentic Official Journal acts control. Article 99 application: 25 May 2018.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document 51f7dd566c68
: unchanged, document 51f7dd566c68
: unchanged, document 51f7dd566c68
: unchanged, document 51f7dd566c68
: unchanged, document 51f7dd566c68
Mapped requirements
Payment Services Act: updated Polish consolidated text
Source check failed
Sejm ELI
Source diagnostics
Lifecycle
Source check failed
Language
pl
Retrieved
11 Sept 2026
Extraction
captured
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
requires-revalidation
Type
legislation
Version
Dz.U. 2026 poz. 623; updated text, footer 21 August 2026
Original: data/country-handbook-evidence/pl/D20260623Lj-delivery.pdf (242 pages). Articles 4(2)(1)-(3), (9), 59ia-59ic and 59if-59ig inspected, including native pages 93-100. Underlying and consolidation metadata captured. Future amendments 875 (Article 12) and 1074 (Article 5) were checked: they concern provider registration/fees, not the mapped basic-account provisions. Their 2027 changes are not current duties. Consolidation/publication is not used as the commencement date.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document 03487c278791
: unchanged, document 03487c278791
: unchanged, document 03487c278791
: changed, document 03487c278791
: unchanged, document 7ffbdb60a64c
Mapped requirements
Delegated Regulation (EU) 2019/758: third-country group AML obstacles
Source check failed
European Commission / EUR-Lex
Source diagnostics
Lifecycle
Source check failed
Language
pl
Retrieved
11 Sept 2026
Extraction
captured
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
unvalidated
Type
legislation
Version
Polish Official Journal text, OJ L 125, 14 May 2019; Articles 1-9
Official Polish PDF obtained by standard Publications Office CELEX content negotiation (Accept application/pdf; Accept-Language pl), without challenge bypass. Original: data/country-handbook-evidence/pl/eu-group-cellar-pl.pdf. Actual original bytes hashed; PDF language/version matched to the previously inspected Polish text. Canonical EUR-Lex text: https://eur-lex.europa.eu/legal-content/PL/TXT/HTML/?uri=CELEX:32019R0758. Polish OJ L 125, 14 May 2019; operative Articles 1-9 inspected. Article 9 application: 3 September 2019. Credit/financial-institution scope is not every national obliged institution.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document f676d5012efe
: unchanged, document f676d5012efe
: unchanged, document f676d5012efe
: unchanged, document f676d5012efe
: unchanged, document f676d5012efe
Mapped requirements
GIIF notice 113: travel-rule evidence, suspicion assessment and reporting
Source changed
General Inspector of Financial Information / Ministry of Finance
Source diagnostics
Lifecycle
Source changed
Language
pl
Retrieved
11 Sept 2026
Extraction
captured
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
requires-revalidation
Type
guidance
Version
Public notice 113, Sections II.1-II.4, inspected 11 September 2026
Original: data/country-handbook-evidence/pl/giif-113-delivery.html. Native Polish guidance inspected. References EBA/GL/2024/11 paragraphs 83 and 55. Customer declaration or screenshots alone are not acceptable technical proof. Section II.4 refers to detailed SIGIIF instructions that are not public; no form fields or secure reporting deadlines are invented. The future goAML field mentioned in II.2 is not asserted to be available now.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: unchanged, document 89482bed09d5
: unchanged, document 89482bed09d5
: unchanged, document 89482bed09d5
: unchanged, document 89482bed09d5
: unchanged, document 89482bed09d5
Mapped requirements
No mapped requirement is available in this selected reading view.
UKNF information on the end of the MiCA transitional period
Source changed
Polish Financial Supervision Authority
Source diagnostics
Lifecycle
Source changed
Language
pl
Retrieved
11 Sept 2026
Extraction
captured
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
requires-revalidation
Type
guidance
Version
Updated 23 June 2026; introductory paragraph and points 1-3
Original: data/country-handbook-evidence/pl/knf-mica-transition-20260623-delivery.html. Native public guidance states the Article 143(3) transition ends on 1 July 2026 and the Polish virtual-currency register is not MiCA authorisation. Point 3's statement about national implementing legislation is expressly dated June; it is not promoted into a verified September absence-of-law claim. This source does not establish a particular provider's permission.
Status basis
A source change or revalidation is awaiting review.
Recent document checks
: unchanged, document ac06f20aba55
: unchanged, document ac06f20aba55
: unchanged, document ac06f20aba55
: unchanged, document ac06f20aba55
: unchanged, document ac06f20aba55
Mapped requirements
EBA Guidelines on remote customer onboarding solutions
Source check failed
European Banking Authority
Source diagnostics
Lifecycle
Source check failed
Language
pl
Retrieved
11 Sept 2026
Extraction
captured
Latest automated check
12 Oct 2026
Check outcome
unchanged
Evidence review
unvalidated
Type
guidance
Version
EBA/GL/2022/15, 22 November 2022; revised Polish version; application 2 October 2023
Original: data/country-handbook-evidence/pl/kas-sanctions-faq-core.pdf. Question 11 checked with current KAS reporting-address heading and national Act Articles 1(2), 6(1)(2). Explicitly includes national Act freezes and conditional owner particulars, but no numerical deadline. Unrelated trade or Russian-counterparty answers are not mapped as current advice on every regime.
Status basis
The source could not be extracted successfully.
Recent document checks
: unchanged, document 3b6019003d71
: unchanged, document 3b6019003d71
: unchanged, document 3b6019003d71
: unchanged, document 3b6019003d71
: unchanged, document 3b6019003d71
Mapped requirements
Country authority or guidance body
Generalny Inspektor Informacji Finansowej (GIIF; GIFI in English)
Poland
Role and responsibilities
Polish financial intelligence authority: receives AML reports, analyses information, exercises AML control powers and administers the AML Act's targeted terrorist-financing restrictions. Supported by the Ministry of Finance's Financial Information Department.
Related sources in this handbook
No source in this selected handbook view is directly labelled with this authority.
Country authority or guidance body
Komisja Nadzoru Finansowego (KNF) / Urząd Komisji Nadzoru Finansowego (UKNF)
Poland
Role and responsibilities
Financial-sector supervisor and its office; UKNF publishes the checked internal-procedure position for KNF-supervised obliged institutions. Supervision must be determined for the actual legal entity.
Related sources in this handbook
No source in this selected handbook view is directly labelled with this authority.
Country authority or guidance body
Szef Krajowej Administracji Skarbowej (Head of KAS)
Poland
Role and responsibilities
Financial-sanctions competent authority identified by MSZ, including specified frozen-assets and derogation matters. Competence is regime-specific and is not interchangeable with GIIF reporting.
Related sources in this handbook
No source in this selected handbook view is directly labelled with this authority.
Country authority or guidance body
Minister Spraw Wewnętrznych i Administracji (MSWiA)
Poland
Role and responsibilities
Maintains the separate domestic sanctions list under the Act of 13 April 2022; not the GIIF Article 118 terrorist-related list.
Related sources in this handbook
No source in this selected handbook view is directly labelled with this authority.
Country authority or guidance body
Ministerstwo Spraw Zagranicznych (MSZ)
Poland
Role and responsibilities
Coordinates Poland's international sanctions policy and publishes the competent-authority allocation; operational responsibilities depend on the relevant measure.
Related sources in this handbook
No source in this selected handbook view is directly labelled with this authority.
