Paweł Kwiecień, Magdalena Kostowska
Commercial companies and partnerships are required to report and update information on all natural persons who control them directly or indirectly. The disclosures are made to the Central Register of Beneficial Owners (abbreviated to CRBR in Polish), using “new filing” for changes in factual circumstances or “revision” when there are manifest errors to be revised. However, it may be unclear what the correct CRBR submission procedure is where a company made its filing but later became aware that some of the disclosures were erroneous or incomplete. In our opinion such submission should be made using the revision procedure, not update. Otherwise, CRBR would, by reference to the same period, feature both erroneous information submitted in the original filing and correct information submitted as a new filing using the update procedure.