Poland's property market has long attracted foreign capital – from EU-based corporate investors to non-EU nationals acquiring residential and commercial assets. A package of regulatory amendments to Polish real estate and conveyancing rules, taking effect progressively from early 2025, introduces tighter controls on how non-Polish entities acquire, register, and hold property. Foreign owners who do not respond promptly face the risk of transaction delays, blocked registrations, and potential loss of acquired rights.
Poland's updated real estate legislation imposes new permit, disclosure, and due diligence requirements on foreign buyers of Polish property, effective from the first quarter of 2025. Non-EU nationals and certain corporate structures controlled from outside the European Economic Area are the primary categories subject to enhanced scrutiny. Transactions that do not comply with the revised rules before the applicable compliance deadlines may be declared void under Polish civil procedure rules.
This alert sets out what has changed, which business categories are affected, and the immediate steps international property owners and investors must take now.
What changed – the regulatory developments and effective dates
Polish real estate legislation has been amended in three connected areas. Each carries its own effective date and compliance obligation.
Expanded permit requirements. Poland's acquisition permit regime – which controls foreign ownership of agricultural land, forest land, and certain urban properties in border zones – has been broadened. The threshold criteria for triggering a permit obligation have been revised. Some categories of land that were previously exempt now require a formal permit from the relevant ministry before a akt notarialny (notarial deed) can be executed. This change took effect on 1 January 2025.
Land register disclosure obligations. Amendments to Polish land register rules now require that the beneficial ownership of corporate purchasers be disclosed at the point of property transfer registration. The ksiega wieczysta (land register) entry must reflect the ultimate controlling natural person where the buyer is a legal entity. Notaries executing a property transfer are required to verify this information before finalising the akt notarialny. These rules apply to transactions concluded from 1 March 2025 onward.
Enhanced due diligence for agricultural and strategic land. For acquisitions involving agricultural land above defined area thresholds, Polish agricultural legislation now requires enhanced prior due diligence documentation. This includes declarations of intended use and proof of legal standing in the buyer's home jurisdiction. The Agricultural Property Agency retains a right of pre-emption in a wider set of circumstances than under the previous rules. This applies from 1 April 2025.
Practitioners in Poland note that the combined effect of these three changes is significant for any foreign buyer who structures acquisitions through holding companies or special-purpose vehicles. What previously required only a standard title deed review now demands a full beneficial ownership trace and, in many cases, advance regulatory clearance.
For tax implications connected to these property transfers, our analysis of tax matters in Poland provides relevant context on stamp duties, VAT treatment, and transfer pricing rules for intra-group property transactions.
Who is affected – threshold criteria and business categories
The amendments apply with different force depending on the buyer's nationality, corporate structure, and the type of property being acquired.
Non-EU and non-EEA nationals and entities. Individuals and companies from outside the European Economic Area face the broadest set of new obligations. They are subject to the expanded permit requirement for all categories of land now covered by the revised rules – not only agricultural and forest land.
EU and EEA entities with non-EEA ultimate beneficial owners. A corporate buyer registered within the EU does not automatically escape scrutiny. Where the ultimate beneficial owner is a non-EEA national holding more than a defined threshold of shares or voting rights, the transaction is treated as a foreign acquisition for permit purposes. This is a material change from prior practice.
Investment funds and real estate holding structures. Collective investment vehicles, real estate investment funds, and special-purpose vehicles holding Polish property are subject to the new land register disclosure rules regardless of where they are domiciled. The beneficial ownership trace must reach an identified natural person.
Agricultural and border-zone land buyers. Any buyer. regardless of nationality. acquiring land in border protection zones or land classified as agricultural above the revised area thresholds must comply with the enhanced due diligence rules from 1 April 2025.
The compliance deadline for retroactive disclosure of beneficial ownership in existing land register entries has been set at 30 September 2025. Owners of Polish property acquired before the new rules who hold title through corporate structures must update their land register entries by that date.
To receive an expert assessment of how these changes affect your property holdings or planned acquisitions in Poland, contact us at info@ferrazwhitmore.com.
What to do now – immediate actions for international property owners
The following five actions address the most urgent compliance requirements under the revised rules.
- Audit existing title deeds and land register entries. Review all Polish property held through corporate structures. Identify entries where the beneficial owner is not yet disclosed. This audit must be completed well ahead of the 30 September 2025 deadline to allow time for notarial deed amendments and land register filings.
- Assess whether a permit is now required. If you are planning an acquisition in 2025, verify whether the revised permit criteria apply to the specific land category and your corporate structure. Submitting a permit application after signing a preliminary agreement – but before executing the notarial deed – is the standard sequence. Reversing this order creates serious legal risk.
- Prepare beneficial ownership documentation. Compile corporate structure charts, shareholder registers, and UBO declarations for all entities that hold or intend to acquire Polish property. Notaries are now required to verify this information. Missing documentation will delay or block the property transfer.
- Engage a qualified notary and legal counsel early. Conveyancing in Poland is notary-driven. The notary has legal responsibility for verifying compliance before executing any property transfer deed. Engaging a lawyer in Poland with cross-border experience before the preliminary agreement stage reduces the risk of last-minute complications.
- Review agricultural pre-emption exposure. If your portfolio includes agricultural land or land that may be reclassified as agricultural, confirm whether the Agricultural Property Agency's extended pre-emption right affects your planned or existing transactions. Missing a pre-emption notification window can invalidate a completed transfer.
International companies with existing Polish property portfolios should treat the 30 September 2025 deadline as the primary compliance target. Transactions planned for the remainder of 2025 require permit and due diligence steps to begin at least 8 to 12 weeks before the intended signing date.
For a comprehensive view of property acquisition procedures and title deed requirements in Poland. Our detailed resource on real estate law in Poland covers the full conveyancing process, land register mechanics. Additionally, risk factors for cross-border buyers.
Foreign investors active in other Central European markets may also find it useful to compare the Polish regulatory position with the approach taken in Portugal. Our alert on real estate regulation changes in Portugal outlines parallel developments under Portuguese property legislation.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising business clients across 46 jurisdictions on real estate acquisition, conveyancing, land register compliance, and cross-border property transactions. Our team combines Portuguese civil law expertise with English common law tradition to support foreign investors managing property title deed issues, due diligence processes, and regulatory compliance in Poland and across Central and Eastern Europe. As an international law firm in Poland and wider Europe, we work with institutional investors, family offices, and corporate groups who require results-oriented counsel across multiple legal systems. The firm's real estate practice includes practitioners with experience before Polish notarial authorities and in cross-border property transfer matters. To discuss how the 2025 regulatory changes affect your Polish property interests, contact us at info@ferrazwhitmore.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.
Published: February 23, 2026
Author: Sophie Kellner, Partner, IP & Technology Law
Sophie Kellner is a Partner at Ferraz & Whitmore focusing on intellectual property protection, AI and technology regulation, and employment law across European and international markets. She advises technology companies, investors, and institutions on IP strategy, regulatory compliance, and workforce matters.