Before a commercial property deal closes in Poland, the collateral picture must be assembled from at least five separate registers. No single source shows the full encumbrance stack. CEIDG is one layer — and a limited one — in a verification chain that also runs through KRS, EKW, Rejestr Zastawów, Rejestr Zastawów Skarbowych, KRZ and Biała lista. This report maps what each source reveals, where each chain breaks, and what remains invisible after all public registers are exhausted.
- What CEIDG shows
- Name, NIP, REGON, registered address, business scope, suspension or deletion status of a sole trader. Source: ceidg.gov.pl · verified August 2026.
- What CEIDG does not show
- Pledges, mortgages, tax liens, insolvency proceedings, or UBO chains above the registered natural person. Source: ceidg.gov.pl · verified August 2026.
- Charge registers
- Two separate systems apply: Rejestr Zastawów (Ministry of Justice) and Rejestr Zastawów Skarbowych (Ministry of Finance). A complete pledge profile requires both. Source: Centralna Informacja / e-Urząd Skarbowy · verified August 2026.
- Insolvency cut-off
- KRZ (krz.ms.gov.pl) covers proceedings opened after 1 December 2021 only. Earlier files are not searchable through this portal. Source: krz.ms.gov.pl · verified August 2026.
- Land register access
- EKW is searchable only by KW number, not by owner name. The KW number must first be retrieved from the ewidencja gruntów. Source: ekw.ms.gov.pl · verified August 2026.
What the collateral stack looks like in a Polish commercial deal
Polish commercial property can carry encumbrances recorded in four distinct systems that do not cross-reference each other. A mortgage appears in the land register (EKW). A registered pledge on equipment or receivables appears in Rejestr Zastawów. A tax lien appears in Rejestr Zastawów Skarbowych. An insolvency trustee's claim appears in KRZ. None of these systems queries the others automatically.
CEIDG is the entry point when the seller is a sole trader (jednoosobowa działalność gospodarcza). It confirms identity, NIP and trading status. That confirmation matters: a suspended or deleted trader cannot validly transfer title. But CEIDG says nothing about what encumbers the asset itself.
When the seller is a company, KRS replaces CEIDG as the identity layer. KRS is free to search and free to download. A certified extract (odpis) costs approximately 30–60 PLN. KRS shows current management, share structure, and any pending dissolution or liquidation proceedings.
| Encumbrance type | Register | Access | Cost | Limit |
|---|---|---|---|---|
| Mortgage (hipoteka) | EKW (ekw.ms.gov.pl) | By KW number only | Free | KW number must be sourced separately from ewidencja gruntów |
| Registered pledge on movables / receivables | Rejestr Zastawów (Centralna Informacja) | Open | DW-1 (pledgor) 20 PLN; DW-2 (object) 20 PLN; odpis DW-4 15 PLN | Covers only pledges registered under the 1996 Act; financial collateral excluded |
| Tax lien (zastaw skarbowy) | Rejestr Zastawów Skarbowych (e-Urząd Skarbowy) | Open search free; wypis/zaświadczenie 50 PLN | 50 PLN for certified document | Covers only tax liens; not general civil pledges |
| Insolvency / restructuring proceedings | KRZ (krz.ms.gov.pl) | Open, free, no login | Free | Proceedings opened after 1 December 2021 only |
| Pre-December 2021 insolvency | MSiG archive (wyszukiwarka-msig.ms.gov.pl) | Open, free | Free | PDF issues only; no structured data; announcements since 1996 |
| VAT status and bank accounts | Biała lista (podatki.gov.pl) | Open, free, no login | Free | Shows registered accounts only; does not reveal undeclared accounts |
| Beneficial ownership | CRBR (crbr.podatki.gov.pl) | Open, free, no login | Free | Accuracy depends on filing by the obliged entity; no independent verification by the register |
| Sole trader identity / status | CEIDG (ceidg.gov.pl) | Open, free | Free | No encumbrance data; no insolvency data; no asset data |
The Biała lista — why bank account verification matters for collateral
Biała lista (the White List of VAT taxpayers) is maintained by the Head of KAS and is free to search without login. It shows VAT status, registered business details, and — critically — all bank account numbers declared to the tax authority.
A payment made to an account not on the list triggers joint and several liability for the buyer's VAT obligations. This is not a theoretical risk in commercial property transactions. The list allows a check against any historical date, which matters when verifying a transaction already signed but not yet settled.
Accessing the land register when the KW number is unknown
EKW is publicly accessible and free. The barrier is structural: the portal accepts a KW number, not an address or owner name. Retrieving the KW number requires a separate query to the ewidencja gruntów i budynków — the cadastral register held at the starostwo (county office). That query may require an in-person visit or a written request, depending on the county.
Once the KW number is known, EKW shows all registered mortgages, their amounts, currency, and ranking. It also shows whether the property is subject to any court-ordered restriction on disposal. The register does not show unregistered encumbrances or contractual restrictions that were never lodged.
The pledge registers — two systems, one verification requirement
Rejestr Zastawów, maintained by the Ministry of Justice through Centralna Informacja, covers pledges registered under the 1996 Act on Registered Pledges. A search by pledgor (DW-1) costs 20 PLN. A search by pledged object (DW-2) costs 20 PLN. A certified extract (odpis DW-4) costs 15 PLN. These are official tariffs.
Rejestr Zastawów Skarbowych, maintained by the Ministry of Finance, covers tax liens. A free search by object is available through e-Urząd Skarbowy. A certified wypis or zaświadczenie costs 50 PLN.
A seller's asset can appear in one register, in both, or in neither. The two registers are not linked. Checking only one produces an incomplete picture. Financial collateral arrangements under the 2004 Act on Financial Collateral Arrangements do not appear in either register.
Insolvency — the December 2021 cut-off
KRZ (Krajowy Rejestr Zadłużonych) at krz.ms.gov.pl is open, free and requires no login. It covers bankruptcy, restructuring, and secondary proceedings opened after 1 December 2021. Search runs by PESEL, NIP, KRS number or case signature.
Proceedings opened before that date were announced in MSiG (Monitor Sądowy i Gospodarczy). The MSiG archive at wyszukiwarka-msig.ms.gov.pl is free and searchable back to 1996. Issues are PDF only; there is no structured data export. A clean result in KRZ does not exclude an earlier insolvency that closed before the system went live.
A complete insolvency check therefore requires both portals. Where a proceeding was opened under the pre-2021 rules and is still active, it may appear in KRZ under its current status even if the opening announcement was in MSiG. This overlap zone requires case-by-case assessment.
The limit of what the sources allow
All registers listed on this page are public. Several are free of charge. What they collectively cannot establish is set out below — not as a caveat, but as a structural fact about the Polish register architecture.
- Financial collateral arrangements under the 2004 Act are not registered anywhere publicly accessible. They exist only in the contract between the parties.
- Pre-December 2021 insolvency proceedings that were closed without public announcement in MSiG leave no searchable trace in any open portal.
- Contractual restrictions on disposal (pre-emption rights, tag-along clauses, shareholder agreement restrictions) do not appear in KRS unless lodged as an entry. Most are not.
- CRBR accuracy depends entirely on the filing entity. The register contains what was declared, not what was verified. Discrepancies between CRBR and the actual UBO structure are not detectable from the register alone.
- EKW section III (rights, claims and restrictions) shows court-ordered restrictions but not private contractual ones. An unregistered easement or usufruct does not appear.
- Tax debts not yet converted to a lien do not appear in Rejestr Zastawów Skarbowych. A tax debt becomes a lien only after a formal decision and registration — a process that takes time.
The report identifies which of the above gaps apply to the specific asset and seller, names the last point in the chain where a source gives a definitive answer, and states where the chain breaks.
Where the sources disagree
CRBR and KRS sometimes show different ownership structures. KRS records the share register as filed; CRBR records the beneficial owner as declared. Where a nominee structure or multi-tier holding is involved, the two entries diverge. The divergence is itself a finding — it does not resolve automatically and requires document-level review.
Biała lista and the seller's own invoice may show different bank accounts. A seller who recently changed accounts and has not updated the KAS declaration presents a payment risk regardless of intent. The report flags this mismatch and states the date of the last Biała lista update for the entity.
What is included at each tier
| Tier | Price (EUR, excl. VAT) | Included | Not included |
|---|---|---|---|
| Signal | €710 | CEIDG / KRS identity and status check; KRZ insolvency search (post-2021); Biała lista VAT status and bank account verification; CRBR beneficial ownership extract; summary of findings with source citations and retrieval dates | EKW mortgage search; Rejestr Zastawów pledge search; Rejestr Zastawów Skarbowych tax lien search; MSiG pre-2021 archive review; financial statements review; document-level KRS review |
| Standard | €1,500 | Everything in Signal; EKW mortgage register extract (KW number retrieval included); Rejestr Zastawów search by pledgor and object (DW-1 and DW-2); Rejestr Zastawów Skarbowych search with certified wypis; MSiG archive review for pre-2021 insolvency announcements; RDF financial statements for the last two available years | Document-level KRS review (filed deeds, shareholder agreements); vehicle and equipment register (CEPiK / historiapojazdu); sanctions and PEP screening; legal qualification of findings |
| Extended | €3,400 | Everything in Standard; document-level KRS review including filed deeds and resolutions; vehicle and equipment check via CEPiK where seller provides registration data; sanctions and PEP screening against EU, OFAC and UN lists; CRBR discrepancy analysis against KRS; three-year RDF financial statements review; written summary of all register gaps with asset-specific commentary | Legal advice; legal qualification of findings; representation; due diligence on title chain prior to current seller; review of unregistered contractual arrangements not disclosed by seller |
Several registers used in this report are public and free of charge. What the fee covers is the removed path: obtaining the KW number before EKW is accessible, submitting DW-1 and DW-2 requests with the correct national identifiers, navigating the MSiG PDF archive, reading Polish-language documents, and assembling findings into a single dated report with source citations.
Frequently asked questions
Does a clean KRZ result mean the seller is solvent?
No. KRZ covers proceedings opened after 1 December 2021. A proceeding opened before that date, or a proceeding filed but not yet adjudicated, does not appear as a KRZ entry. A clean KRZ result establishes the absence of a post-2021 registered proceeding — nothing more.
Can EKW be searched by the property address?
No. EKW accepts only the KW number. The KW number is obtainable from the ewidencja gruntów i budynków at the relevant starostwo. That step is included in the Standard and Extended tiers.
What is the difference between Rejestr Zastawów and Rejestr Zastawów Skarbowych?
Rejestr Zastawów (Ministry of Justice) covers registered pledges under civil law — pledges on movables, receivables and other rights. Rejestr Zastawów Skarbowych (Ministry of Finance) covers tax liens specifically. An asset can appear in both, in one, or in neither. Both must be checked to produce a complete pledge picture.
Is CRBR reliable as a UBO source?
CRBR contains what the obliged entity declared. The register does not independently verify declarations. Where the CRBR entry diverges from the KRS share register, the divergence is flagged in the report. Resolution requires document-level review beyond what any public register provides.
How long does the report take?
Signal tier: typically three to five business days from receipt of the seller's NIP and KRS or CEIDG number. Standard and Extended tiers: five to ten business days, depending on the speed of cadastral office response for KW number retrieval.
Disclaimer: This report is a factual compilation from official registers and public sources. It is provided for informational purposes only, does not constitute legal advice, and contains no legal qualification of the facts established. KORDECKI & Partners assumes no liability for actions taken or not taken based on this material. For advice regarding your particular situation, please contact info@kordeckipartners.com.