Opening a company bank account in Poland: why it takes so long

Registering a Polish company can take a day, and head office plans around that number: first invoices, first salaries, the first supplier who wants to be paid. Then the bank’s questionnaire arrives. What will the account be used for? What turnover do you expect? Who stands at the top of the group - and could we have the register extract of the Luxembourg holding company, apostilled? Two weeks later the file is still “under review”. The slow part of setting up in Poland is usually not the company. It is the bank account - and it is slow for reasons you can work with.

Why does the bank take longer than the registry court?

Because it is checking something much bigger. The registry court looks at one company: are its articles, its board and its filing in order? The bank looks at who you are.

A bank is an obliged institution (instytucja obowiązana) under the Anti-Money Laundering Act (ustawa o przeciwdziałaniu praniu pieniędzy oraz finansowaniu terroryzmu, “AML Act”). Before it takes on a customer it must apply customer due diligence (środki bezpieczeństwa finansowego) - in bank language, KYC. For a company that means four things (Art. 34): identify the company and verify it; identify its beneficial owners - the natural persons at the top - and understand the ownership and control structure between them and the company; identify everyone who will act for the company and check their authority; and find out what the relationship is for.

If the bank cannot complete any one of these, the Act leaves it no discretion: no business relationship, no transactions, no payments through the account (Art. 41).

In plain terms: until the last document is in, the answer is “not yet” - and from the outside, “not yet” looks exactly like “no”.

For a Polish subsidiary of a foreign group, “the structure in between” is your group chart: the Dutch holding company, the German parent, the fund or the family above it, with evidence for each layer from its own country. The bank also carries the risk if it gets this wrong - fines for AML failings run to millions of euros - while a newly formed subsidiary with a small balance earns it very little. Its incentives all point one way.

How long, then? In my experience at least 2 weeks for a simple, familiar business with a short structure. With several tiers, a trust or a foundation in the chain, or a less usual jurisdiction, plan for 1 to 2 months. The longest I have seen took 2 months - reviewing the structure and answering the bank’s follow-up questions. That is an extreme, but it happens. And a bank, procedures aside, is not the fastest-moving organisation in the world.

For precision: the Act does let a bank sign the account agreement before its checks are complete - but no transaction may go through the account until the company and its beneficial owners have been identified and verified (Art. 39(3)). That gets you an account number early, not an account you can pay from.

Before or after registration?

It depends on how the company comes into being. When a group builds a new company, my clients usually open the account while it is a company in organisation (spółka w organizacji) - after the articles of association are signed and before the entry in the National Court Register (KRS). When a group buys a ready-made company, the account usually comes after the shares have been taken over, so the bank reviews the buyer’s group, not the seller’s.

Opening early has one consequence worth knowing. For a limited liability company the Act asks the bank to obtain confirmation of the company’s entry in the Central Register of Beneficial Owners (CRBR) (Art. 39(1a)) - and a company in organisation cannot have one yet: the report is due within 14 days of the KRS entry. So the bank works from your documents, and the CRBR report your board files later has to tell the same story, because the bank compares the two (more on the CRBR).

The share capital needs an account too. That timing question - and why the S24 promise of paying it in within 7 days of registration is largely a mirage - is covered in my article on set-up timelines.

What will the bank ask for?

The bank wants to know as much as possible about two things: the business and the structure. Expect questions at every level. The table shows one typical pattern, not a fixed list: every bank has its own, and some ask for more, some for less.

Two things tend to surprise foreign groups. The bank may ask for a legal memorandum on the structure from a law firm in your own jurisdiction, explaining who owns and controls what under your law. And it may ask again, with an apostille, for documents you have already sent. The Act itself asks only for verification against a current register extract or another reliable, independent source; apostilles and translations beyond that are the bank’s own policy.

What turns a standard review into an enhanced one?

The Act scales the checks to the risk. Some features of a group move the file into enhanced checks - more questions, more documents and, in some cases, sign-off from the bank’s senior management - and each one adds time (Art. 43–46):

• a structure that looks unusual or excessively complex for the business it runs;
• a vehicle that exists to hold personal assets, or shares whose rights are exercised by someone other than the shareholder (nominee arrangements);
• a link to a high-risk country, or to one under UN or EU sanctions - for countries on the EU’s high-risk list the bank must also establish where the owners’ wealth and the funds come from;
• a politically exposed person among the beneficial owners;
• onboarding with nobody physically present, unless that is offset by electronic identification or an eIDAS trust service.

In plain terms: the bank is not asking whether your group is honest. It is asking whether it can prove, on paper, that it checked. A trust or a family foundation in the chain can be entirely legitimate - and still turn 2 weeks into 2 months.

How do you make it faster?

You cannot make the bank skip a step. You can make sure it never waits for you.

Start as soon as the decision is taken. Contact the bank when head office decides to set up or buy in Poland - not when the Polish company exists. Collecting the documents takes time, and most of them concern the group, not the Polish company, so they can be ready long before it is. The account itself can be opened once the articles are signed (a new company) or the shares are yours (a ready-made one).

Give the bank more than it asks for - at the start. The bank will want the full group structure anyway, so hand it over on day one, with commercial-register extracts and beneficial-ownership-register extracts for every country in the chain, where they exist. It will still come back for something - an extra document, an apostilled copy - but you stay one step ahead of the file instead of one step behind it. Check that the chart matches what your Polish board will report to the CRBR.

Use a bank that already knows the group. It sometimes helps, especially when the group already holds accounts with that bank - which also means it has a corporate relationship manager, and that can speed things up. It does not change the rules: the bank must still run every procedure. For precision: the Act does let a bank rely on checks by another entity in its own banking group (Art. 47(5)), but the Polish bank stays responsible for them - group knowledge shortens the file; it does not replace it.

Decide early who will be identified, and how. Each person who will act for the company must be identified and their authority checked. If the board has more than one member and the articles say nothing else, two board members act jointly (or one together with a commercial proxy holder), so that is usually more than one person, often abroad. Identification can take place in person or by video, and some banks let a board member identify at a branch of their own network abroad - at the bank’s branch in Paris, say - with no identity check in Poland and no notarised documents. Ask the bank which of these it offers before anyone travels.

Why not run the Polish company on the group’s existing account?

Nothing in Polish company law says the account must be at a Polish bank. Tax practice does. Polish customers check the VAT white list (wykaz podatników VAT) before they pay, and it shows only settlement accounts held in the Polish banking system - at a Polish bank or the Polish branch of a foreign one - that the company has declared to the tax office (Art. 96b of the VAT Act). A foreign account never appears there. If a customer pays an invoice above PLN 15,000 into an account missing from the list, it cannot deduct the cost for corporate income tax (Art. 15d of the Corporate Income Tax Act) and may become jointly liable for your VAT (Art. 117ba of the Tax Ordinance, Ordynacja podatkowa), unless it notifies its tax office within 7 days of ordering the transfer.

In plain terms: your Polish customers will not want to pay into an account the list does not show. This is a signpost, not tax advice - confirm the details with your Polish tax adviser.

What this means for you

Put the bank account on the critical path of the project, next to the board members’ electronic signatures - not after registration, as an administrative afterthought - and do not promise invoices, salaries or supplier payments until the account works. The one thing that shortens the wait is under your control: how complete your file is on day one.

Watch out

• KYC does not end when the account opens. The bank keeps monitoring the relationship and must update its file when the company’s details change - a new board member, a new owner anywhere up the chain. If it cannot complete the update, the same rule applies as at the start: no payments through the account, and the bank must end the relationship. Tell the bank about upstream changes before it finds out, and update the CRBR at the same time.
• The rulebook moves to EU level in July 2027. From 10 July 2027 the customer due diligence rules come from an EU regulation that applies directly (Regulation (EU) 2024/1624, the AMLR). The core checks stay - the customer, its beneficial owners, the people acting for it, the purpose of the relationship, ongoing monitoring - and the list spells out two more: a sanctions check and the nature of the customer’s business (Art. 20(1) AMLR).

Next steps

1. As soon as the decision to set up or buy is taken, choose the bank - start with one that already knows the group - and contact it. Do not wait for the Polish company to exist.
2. Ask head office for the full group structure up to the natural persons at the top, with commercial-register and beneficial-ownership-register extracts for every company in the chain.
3. Write one page on the Polish company’s business: what it will do, expected turnover, where the money comes from and where it goes.
4. Ask the bank what it needs and in what form (apostille, sworn translation, a legal memorandum on the structure) before you send anything.
5. Settle who will be identified and how: in person, by video, or through the bank’s network abroad.
6. Open the account as soon as the company can hold one: once the articles are signed (a new company) or the shares are yours (a ready-made company).