Last call to register activities for companies or trusts and activities in the field of virtual currencies

According to the amended Anti-Money Laundering and Counter-Terrorism Financing Act, activities performed for companies and trusts and activities in the field of virtual currencies have become regulated activities within the meaning of the Entrepreneur Law of 6 March 2018.

What entities are obliged to get registered?

The legislator identified entities which are obliged to be entered in the register. These are:

a. entrepreneurs who carry on activities for companies or trusts, consisting of:

  • providing a registered office, a business address or a mailing address and other similar services to a legal person or an organisational unit having no legal personality,
  • establishing a legal person (corporation) or an unincorporated organisational unit (having no legal personality),
  • holding the function of a management board member or enabling another person to hold such a function or a similar function in any legal person or unincorporated organisational unit,
  • acting or enabling another person to act as a trustee, created by way of a legal transaction;
  • acting or enabling another person to act as a person exercising rights from shares or stock, for an entity other than a company listed on the regulated market, subject to the requirements for disclosure of information according to the European Union law or equivalent international standards.

b. entrepreneurs operating a business in the field of virtual currencies, consisting of:

  • exchange of virtual currency to legal tender;
  • exchange of virtual currency to another virtual currency;
  • intermediation in the exchanges referred to above;
  • maintaining accounts to enable authorized persons to use virtual currency units, including transactions of their exchange.

Entrepreneurs whose business is subject to the above regulations must obligatorily get registered, which means that they need to satisfy certain conditions such as having no criminal record or holding an expert opinion on the regulated business they operate.

The deadline for filing an application for registration is approaching

If you operate a business in the above area, you need to remember about the obligation to be registered by 30 April 2022. After an application has been filed, the authority in charge of registers makes an entry in the relevant register within 14 days.

Entities which commence their business in this field must obtain an entry in the register before they start this type of activity.

Sanctions for failure to register

If an entity which operates a business for companies of trusts or a virtual currency business without prior registration with the relevant register may be penalized with a fine of up to PLN 100 thousand.

Do you need assistance in complying with the registration duty?

If you need support with registration, we are at your service.


Katarzyna Komulainen Partner, Warsaw

T: +48 22 690 08 77
M: +48 606 760 836

Piotr Krupa Partner, Katowice

T: +48 32 731 68 52
M: +48 502 109 333