After forming a company in Poland: CRBR, ZUS, VAT calendar

When you form a company in Poland you are entered in the KRS, receive a NIP and a REGON, open a bank account and sign with an accountant. For most Turkish founders "formation" ends there. In fact it begins there: in the weeks after registration there is a series of obligations with deadlines counted in days, and none of them is an automatic part of the KRS entry. This article is the calendar for those first ninety days.

Short answer: After the KRS entry the order is: the beneficial-owner filing in the CRBR (14 days, Saturdays and holidays not counted), taking over the e-delivery inbox (opened automatically at registration, you appoint its administrator), the supplementary tax-office form (NIP-8), VAT registration (VAT-R) before the first invoice, ZUS filings within 7 days of the first insured person, handover to accounting and KSeF e-invoicing access. Put them in a calendar; a missed filing can carry a penalty, and banks check these registers too.

Day 0: what the KRS entry starts, and what it doesn't

With the registration decision the company gains legal personality; NIP and REGON are assigned automatically, the ZUS payer record is created from KRS data, and the e-delivery address is opened during registration. What does not happen by itself: the beneficial-owner filing, management of the e-delivery inbox, bank-account and bookkeeping details for the tax office, VAT status, the transaction tax on share capital, and ZUS filings if you have staff. The clock runs from the registration date, not from the day you found out about it.

CRBR: the beneficial-owner register, 14 days

The CRBR (Centralny Rejestr Beneficjentów Rzeczywistych) is a public register, rooted in EU anti-money-laundering rules, that requires every company to answer "who is really behind it". The beneficial owner is the natural person who ultimately controls the company: whoever directly or indirectly holds more than a quarter of the shares, or exercises decisive influence another way. In a single-shareholder Sp. z o.o. that is you; with two equal shareholders, both of you. If the shares are held through a Turkish company, the chain goes up to the natural person behind it; "the company is owned by a company" is not an accepted answer.

Deadline: 14 days from the KRS entry; Saturdays and public holidays are not counted. Every later change (shareholder, shareholding, management) again within 14 days. The filing is made by a person authorised to represent the company, i.e. a board member; it is free; a proxy cannot do it.

Why it is the most skipped obligation: it is not part of the KRS entry but a separate system; the lawyer who handled formation won't do it unless it is in the engagement; the deadline slips by in the excitement of the launch. The statutory penalty is up to PLN 1,000,000; in practice, of the more than fourteen hundred penalty decisions issued by 2026, the average is around ten thousand złoty, and the great majority went to companies that never filed at all. The assumption "small company, nobody looks" is wrong: the register is cross-checked against the KRS, and banks ask for the CRBR entry when opening accounts and in periodic reviews.

If you are late: file now, with the true dates. A late filing does not erase the delay, but it shortens the period of breach and counts in your favour in any penalty assessment.

The e-delivery inbox: opened automatically, not read automatically

Every company registered in the KRS since 2025 receives an e-delivery address (e-Doręczenia) at registration. Since 2026, authorities send correspondence requiring proof of delivery to this inbox, and a message there that nobody opens counts as delivered on the day after 14 days have passed. The job in the first 90 days is simple but expensive to skip: appoint an inbox administrator, make sure the notification e-mail goes to an address that is read, and put a weekly check in someone's job description. We covered the deadlines of letters from authorities in a separate article; the same rules apply to the electronic inbox.

Tax office: NIP-8, transaction tax, VAT

NIP-8. Information the KRS does not pass to the tax office (bank account, who keeps the books, where the books are kept) is filed by the company itself; the general rule is 21 days from registration, or 7 days if you will pay ZUS contributions. Reporting the bank account matters in its own right: if your account does not appear on the tax office's "white list", your customers may be unable to deduct payments made to you.

Transaction tax on share capital (PCC). If the articles were signed before a notary, the notary collects it; if the S24 template system was used, the company itself files the PCC-3 return and pays 0.5% of the share capital. Note: the 14-day deadline runs not from the KRS entry but from the day the articles were signed in S24, so it usually expires before the company is even registered. This is the item most often missed in companies formed via S24.

VAT registration (VAT-R). A Sp. z o.o. is not a VAT payer automatically. Registration via VAT-R is required before the first VAT-able transaction; if you will trade within the EU, the VAT-EU registration (PL prefix to the NIP) is requested on the same form. During registration the tax office may ask for documents about the address, the activity and the shareholder, and this can take a few weeks; plan the date of the first invoice accordingly. If you will bring goods from Turkey, the EORI number is obtained in this period as well.

ZUS: who and when

The company's ZUS payer record is created automatically from KRS data; a Sp. z o.o. without employees or contractors does not need to register separately with ZUS. Within 7 days of hiring the first employee or insured contractor, the filings are made. One exception has its own rule: the shareholder of a single-shareholder Sp. z o.o. is treated as insured in their own name in the Polish social-security system from the day of registration and pays full contributions (no start-up relief); with two or more shareholders there is no such obligation. This difference should be known when choosing the structure; discovered later, it produces back-dated contribution debt.

Handover to accounting and KSeF

A Sp. z o.o. keeps full books (pełna księgowość); before the first month closes, the agreement with a certified accountant, the document flow and the invoicing setup should be in place. Access to the KSeF e-invoicing system, made mandatory in stages during 2026, and the accountant's authorisation are set up in this period too; details in our KSeF article. The monthly VAT return (JPK_V7) and the annual CIT return sit with the accountant; your job is to deliver documents on time and complete.

What a shareholder in Turkey does

The CRBR filing, the e-delivery inbox and most tax matters require an electronic signature: a qualified e-signature or Poland's trusted profile. A shareholder living in Turkey has neither, and obtaining one takes time; the trusted profile needs identity verification, the qualified signature an application to a provider. Because a proxy cannot make the filing, this calendar slips without a board member whose signature is ready. That is why one of the questions we ask our clients in Turkey who plan a formation, in the first call, is: who will sign, and is the signature ready?

First 90 days checklist

Within 14 days of signing the articles: PCC-3 (if formed via S24; don't wait for registration).
Day 0–14 from registration: CRBR filing; administrator for the e-delivery inbox.
Day 0–21: NIP-8 (bank account, accountant, address of the books).
Before the first invoice: VAT-R and, if needed, VAT-EU, EORI.
Within 7 days of the first employee: ZUS filings; in a single-shareholder company, the shareholder's own insurance.
First month: accounting agreement, document flow, KSeF access and authorisation.
Ongoing: CRBR and KRS updates within 14 days of any shareholder/management change; weekly check of the e-delivery inbox.

Frequently asked

Our company was formed months ago and we never filed the CRBR. What now?

File immediately, with the true dates; a late filing is always better than none. Then check the inbox for a penalty notice; if one has arrived, the appeal and reduction route depends on the amount and the reasoning, and we assess it with the accountant or lawyer partner.

Doesn't the accountant do all this?

Some of it, if the engagement says so; not the filings that require the signature of a person authorised to represent the company, such as the CRBR and the e-delivery inbox. Who does what should be settled together with the formation engagement.

Do you keep this calendar?

Yes. We draw up the compliance calendar for the first ninety days after formation, write down who owns each line, set up signatures and access from the start, track the dates and send you written updates. Returns and tax opinions come from the certified accountant partner; the authorities decide.

Sources

Last checked: 26 September 2026. This article is general information; your own case needs assessment by a licensed partner.

If your company is formed or about to be, let's draw up the calendar together: Tell us your situation or see the Start a company page.

This article is for information only and is not legal or tax advice. Basis: the AML Act (CRBR, articles 58–60 and 153), the e-Doręczenia Act, official ZUS and tax-office guidance, as of September 2026. For your own case the last word rests with the certified accountant and lawyer partners.

Author

Savaş Dere · Founder, CEO

Close to twenty years in software and e-commerce: web and application development, automation, digital products. At Senavia he runs process design, the technology infrastructure and integrations; a founder who has been through company formation and settling in Poland himself.

Meet the team

The first 90 days after forming a company in Poland: CRBR, ZUS, e-delivery, VAT