Electronic Filing of Notarial Deeds in Property Purchases by Foreigners — the President Has Signed the Amendment

On 18 August 2026 the Act of 17 July 2026 amending the Act on the Acquisition of Real Estate by Foreigners and the Notaries Act was published. The new provisions enter into force three months after publication, that is in November 2026.

I. What is changing?

Until now, when drawing up notarial deeds concerning the acquisition of real estate by foreigners (as well as the acquisition or subscription of shares in companies that own real estate or hold it in perpetual usufruct), notaries sent copies of those deeds to the minister responsible for internal affairs in paper form. That duty follows from Article 8a(1) of the Act on the Acquisition of Real Estate by Foreigners and must be performed within 7 days of the document being drawn up.

The amendment does not introduce a new reporting duty — it changes only the way it is performed. Once the new provisions take effect, notaries will transmit the required documents exclusively by electronic means, through the Central Repository of Electronic Copies of Notarial Deeds (Centralne Repozytorium Elektronicznych Wypisów Aktów Notarialnych, CREWAN).

II. How will transmission through CREWAN work?

Under the new Article 8a(1a)–(1d) of the Act on the Acquisition of Real Estate by Foreigners and the amended Article 92a of the Notaries Act:

• the notary places an electronic copy, duplicate or extract of the document in the Repository, signing it with a qualified electronic signature, in a format that allows the content to be searched;
• the National Notarial Council (Krajowa Rada Notarialna) promptly forwards that document through the IT system to the minister responsible for internal affairs;
• once the document is placed in the Repository, the notary receives an electronic confirmation stating the document number and the exact date and time of entry into the system; that confirmation is attached to the original deed, and a second copy is given to the party to the transaction;
• for placing the document in the Repository, the notary charges the parties a fee, which is then passed on to the National Notarial Council.

The seven-day deadline for transmitting the documents remains unchanged — only the channel through which the information reaches the authority is different.

III. Implementing regulations

The Act provides for two implementing regulations:

1. the minister responsible for internal affairs — after consulting the National Notarial Council — will determine how long documents are retained in the Repository, together with the amount of the fee for placing them there and the manner of its payment;
2. the Minister of Justice, in agreement with the minister responsible for digitisation and after consulting the National Notarial Council, will determine how electronic copies and extracts are produced, the organisational and technical conditions for placing them in the Repository, and how notice of interruptions in access to the system is to be given.

Until the new regulations are issued, the existing implementing provisions adopted under Article 92a § 7 of the Notaries Act cease to have effect on the date the Act enters into force.

IV. Transitional provisions

The Act contains an intertemporal rule: documents drawn up before the new provisions take effect remain governed by the existing rules, meaning they may still be transmitted in paper form.

V. What does this mean in practice?

For notaries, the change means adapting internal procedures to an electronic document flow and accounting to clients for the fee for placing the copy in the Repository. For the parties to the notarial transaction — in practice, foreigners acquiring real estate in Poland and entities acquiring shares in companies that own real estate — the change is primarily technical and does not alter the scope of their own obligations towards the authorities.

The purpose of the amendment is to streamline and tighten the supervision of real-estate transactions involving foreigners, through a faster, more secure and more readily analysable electronic flow of information between notaries and the minister responsible for internal affairs.