CWTON for Foreign Owners 2026: Guide for UK, US and Irish Owners

CWTON for Foreign Owners 2026: How to Prepare for Registration as a Non-Resident (UK, US, IE)

> **NOTE - LEGAL STATUS (July 2026):** The draft Polish implementing act (UC135) has not yet been passed, and the CWTON system has not gone live - registration is currently physically impossible. According to the Ministry, the realistic launch is around 15 October 2026 (some sources indicate as late as Q1 2027). This guide shows how to prepare in advance, not how to register in a system that does not yet exist.

An owner of a Krakow flat with a registered address in London, New York or Dublin will have exactly the same CWTON registration duties as a Polish resident. The main difference is the route to obtaining a way to authenticate on gov.pl and, optionally, a power of attorney. Below we explain what is worth preparing today, before the system launches.

CWTON (Central Register of Tourist Accommodation Facilities) is to be created in connection with EU Regulation 2024/1028 of 11 April 2024. The draft Polish act makes no exemption for foreign owners. A British investor who bought a flat near Krakow's Planty after Brexit, an American with a flat under the Tatra mountains and an Irish citizen with a flat on Dluga street will - once the system starts - have to register their property in CWTON in exactly the same way as a Polish resident.

Who Will Be Covered by CWTON as a Foreign Owner

Under draft act UC135 implementing Regulation 2024/1028, the duty to register in CWTON is to apply to anyone offering short-term tourist rental (STR) services in Poland, regardless of country of residence. What matters is the location of the property, not the country of residence of the owner. This means:

• UK citizen owning property in Poland: will have to register each property separately
• US citizen owning a flat in Sopot: same duty
• Irish citizen leasing a flat with subletting rights: will also need CWTON
• A foreign company holding a Polish property: registers as a foreign entity

Income from Airbnb, Booking.com, Vrbo and other platforms is not the criterion. What counts is the simple fact of offering accommodation shorter than 30 days. Note, though, that until CWTON goes live, Polish listings are not being removed from platforms for lack of a number - the registration number field is optional, because there is no register to verify against yet.

What to Sort Out Today: the Commune Register

Before CWTON launches, the only genuinely operating "register" is the entry of the property in the register of other establishments providing hotel services, kept by the local commune head (arts. 38-39 of the Hotel Services Act). A foreign owner can and should complete this today, regardless of CWTON status. It is a good first step that puts the property's legal situation in order.

First Preparatory Step: NIP (Polish Tax ID)

To register a property as a foreign owner in the future, you will likely need a Polish NIP, issued to an individual not running a business or as a foreign entity. NIP is issued by the tax office competent for non-residents. The application can be filed in person, by post or via a representative; waiting time varies (roughly from a few to a dozen or so working days). A NIP is also needed to settle rental tax in Poland, so it is worth handling early.

Second Step: How to Authenticate on gov.pl

The CWTON system, like other gov.pl services, is to require authentication via Trusted Profile (profil zaufany), e-ID or qualified electronic signature. A foreigner has two practical routes to a Trusted Profile today:

Option A: Polish consulate in your country of residence

An owner from London, New York or Dublin can visit the competent Polish consulate with a passport to confirm their identity for a Trusted Profile. The exact rules, required documents and any fees are published by each consular post - check them directly on the relevant consulate's gov.pl page, as procedures change.

Option B: Polish bank with a non-resident account

Some Polish banks offer non-resident accounts opened with remote verification. Once the account is open, you can usually set up a Trusted Profile through online banking in a few minutes. This is often the fastest route for people who need a Polish account for platform payouts anyway.

A caveat on qualified electronic signatures: after Brexit, signatures issued by UK Trust Service Providers (UK TSPs) are no longer automatically recognised in the EU under eIDAS. If you want a qualified signature, choose a certificate issued by an EU-based provider.

Third Step: Power of Attorney for Someone in Poland

A convenient route for an owner who does not want to fly to Poland twice is to grant a power of attorney to a person in Poland. In practice, it is worth having the power of attorney:

• Drafted in Polish or translated by a sworn translator
• Bearing an apostille (Hague Convention 1961) if issued in the UK, US or IE
• Clearly stating the scope: matters related to registering the property, NIP, any declarations
• Notarised as to the signature, where the given act requires it

Exact costs (notary abroad, apostille, sworn translation in Poland) vary by country and firm - it is worth asking for a quote in advance.

Fourth Step: Registering the Property in CWTON (Once the System Launches)

With your NIP, an authentication method and an optional representative ready, you will be prepared for the actual registration as soon as the system starts. The procedure is to be the same as for residents. The exact set of form fields has not yet been officially announced - do not rely on "sample" fields or number formats circulating online, as none has been confirmed. Instead, prepare the typical property documents: proof of title to the premises (Polish notarial deed), a fire-safety declaration, and house rules.

Taxes: Tax Residence and Rental in Poland

CWTON registration will not change your tax residence. A UK owner remains a UK tax resident, but income from renting property located in Poland is taxed in Poland (income from immovable property is taxed in the state where it is located, under the double taxation convention). In practice:

• Private rental is settled under the ryczalt flat-rate: 8.5% up to PLN 100,000 of revenue and 12.5% above (the only form available for private rental)
• If you run the rental as a business, general rules (the tax scale) with cost deduction are possible
• The owner pays and settles the tax as the taxpayer - there is no mechanism whereby a platform or a "Polish payer" withholds 20% at source or files IFT-1R on your behalf. IFT-1R is an information return filed by a payer in other situations and does not apply to this rental model.

On the UK side, the income is included in your Self Assessment, and double taxation is relieved through Foreign Tax Credit Relief. Always confirm the details with a tax adviser.

Renting via a Polish Company: an Organisational Alternative

Some UK and US investors set up a Polish sp. z o.o. (limited liability company) to simplify administration. A company seated in Poland has a KRS, NIP and REGON, and an accountant can set up a Trusted Profile for the management board. The "company or personal" decision depends on scale and tax goals - a topic for separate analysis with an adviser. See the detailed comparison: Polish LLC for STR: When to Switch From Sole Proprietorship.

Most Common Mistakes Foreign Owners Make in Preparation

From our practice, the most common slip-ups at the preparation stage:

• Leaving the NIP to the last minute: it can delay the whole process
• Power of attorney without an apostille or sworn translation: a notary or office may not accept it
• Counting on a UK qualified signature (UK TSP): after Brexit it is not automatically recognised in the EU
• Skipping the commune register entry: this is already a binding obligation today
• Unsettled tax matters: rental income in Poland must be reported regardless of CWTON

Frequently Asked Questions

Do I need to travel to Poland to prepare for CWTON?

Probably not. Most steps can be handled remotely: a Trusted Profile via a Polish consulate or a Polish bank for non-residents, a NIP by post or via a representative, and the CWTON registration itself - once live - online from anywhere. A trip to Poland is usually needed only when buying property.

How long will the whole process take for a UK owner?

The most time-consuming parts are usually the NIP and the apostille, not the registration itself. Because the CWTON system is not operating yet, there is no "20 May deadline" today - instead there is time to calmly gather documents before the system launches (per the Ministry, around 15 October 2026, possibly later).

What about BNO (British National Overseas) and pre-settled status in the UK?

UK immigration status has no impact on CWTON duties in Poland. What counts is the location of the property (Poland) and your right to dispose of it. BNO, pre-settled, settled - the CWTON rules will be identical.

Will CWTON be issued to the owner or to a representative?

To the person or entity holding the right to dispose of the property. A representative only acts on your behalf; responsibility for compliance sits with the owner. The power of attorney should be specific and in writing.

Can a foreign company register CWTON?

Per the draft, yes - as a foreign entity with a Polish NIP. This does not, however, automatically require appointing a "tax representative": a tax representative is a VAT-law institution for non-EU entities, not a condition for CWTON registration. Discuss bookkeeping and returns with a tax adviser.

What if I bought the flat before Brexit and have residence in PL?

Residence status does not affect the duty itself - if the flat is in Poland and you rent it short-term, you will need CWTON. Residence in Poland may only simplify setting up a Trusted Profile (you can do it at a Polish office instead of the consulate).

Need help getting through the whole process without errors? Check the Standard Package HostReady: a complete document set (house rules, fire safety declaration, GDPR clause, guest register) and preparation for CWTON registration, designed by STR specialists experienced in serving foreign investors.

Don't want to search for templates and regulations on your own? The HostReady Package includes complete documentation, ready-to-use templates, and checklists - everything you need for CWTON registration and legal short-term rental, ready to use right after purchase.

--- *Legal note: This content is informational and does not constitute legal or tax advice. Legal status: July 2026. EU Regulation 2024/1028 applies directly from 20 May 2026, but the practical obligations for owners and platforms depend on the adoption and entry into force of the national implementing act (UC135), which remains a draft. For tax and cross-border matters, consult a tax adviser or lawyer.*