If you are an entrepreneur cooperating with foreign contractors, you may be required to submit reports to the National Bank of Poland (NBP). In practice, reporting obligations to the NBP apply to many entities conducting business activities – not only large corporations or financial institutions, but also small and medium-sized entities. So when does such an obligation arise and what exactly needs to be reported?

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Who is subject to reporting obligations?

The reporting obligation may apply to both legal entities, such as limited liability companies, joint-stock companies and individuals running business activities. These entities are required to report if they conduct transactions with non-residents (foreign entities) and meet certain criteria.

Therefore, the reporting obligation may apply to entities that identify, among others, the following events:

  • foreign investments (investments of Polish companies abroad and foreign investments in Poland),
  • loans granted or received from foreign entities,
  • occurrence of receivables or liabilities arising from the delivery of goods and services with foreign entities (e.g. licenses, consulting, outsourcing),
  • holding bank accounts abroad,
  • holding shares by a foreign entity in the equity capital of a Polish entity or shares in foreign companies by a Polish resident.

When does the reporting obligation arise?

In the case the total value of assets and liabilities related to cross-border turnover exceeds the reporting thresholds specified in the regulation on providing NBP with data necessary to prepare the balance of payments and the international investment position [1], the entity is required to submit reports via the NBP reporting portal. However, the reporting deadline is not the same for all entities.

If the total value of assets and liabilities mentioned above amounts to:

  • from 3 to 10 million zlotys

Entities that have not reached the reporting thresholds but have assets or liabilities (receivables or liabilities) related to cross-border turnover of goods or services worth at least 3 million zlotys at the end of the year are required to submit quarterly reports to NBP within 26 days after the end of the quarter.

In this case, quarterly reports include only information on foreign trade, including paid or received advances.

  • between 10 and 300 million zlotys

Entities whose total amount of assets and liabilities specified in the NBP forms exceeds 10 million zlotys but does not exceed 300 million zlotys are required to submit quarterly reports within 26 days after the end of the quarter.

  • above 300 million zlotys

Entities whose total amount of assets and liabilities specified in the NBP forms exceeds 300 million zlotys are required to submit monthly reports within 20 days after the end of the month.

Additionally, reporting obligations also apply to entities that hold at least 10% shares in foreign companies and entities in which foreign companies hold at least 10% shares – such entities are required to submit annual reports by May 31 of the following year. This obligation also cover entities having a branch located abroad as well as branches of foreign enterprises located in Poland.

How can we help?

It is worth regularly verifying whether events causing reporting obligations to NBP have occurred and ensuring that the required data is submitted on time and in accordance with the requirements. Failure to fulfill reporting obligations may result in financial penalties based on the provisions of the Foreign Exchange Law. In case of doubts, it is worth consulting the situation with an external advisor or directly with NBP (Statistics Department).

Crido specialists can support you in:

  • verification process whether the company conducts transactions with foreign entities subject to mandatory reporting,
  • analysis whether the thresholds specified by NBP have been exceeded, and if so - what reporting obligations apply to the company (monthly/quarterly/annual),
  • contact with NBP and registration process on the NBP reporting platform,
  • preparation of data in the required format and submission of forms via the NBP reporting portal.

[1] Regulation of the Minister of Development and Finance of August 9, 2017 on the provision National Bank of Poland with data necessary for the preparation of the balance of payments and international investment position (Journal of Laws of 2024, item 1746)

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