01No PESEL: the law allows it, the bank decides
Art. 36 of the Polish AML Act expressly covers a customer without a PESEL: the bank records the name, citizenship, date and country of birth, and the series and number of the identity document. Nothing in the Act bans opening an account without a PESEL, so "PESEL first" is the internal rule of a particular bank. The practical point: a refusal at one bank says nothing about the next. We establish the requirements in advance, and where a PESEL can be obtained quickly we advise starting with it.
02A document the bank will not accept
The Act requires an "identity document" but gives no list (art. 37), so every bank sets its own catalogue. A passport is rarely a problem, and legal stay is shown by a residence card, a visa or an entry stamp. Temporary documents are harder: in 2026 the Polish Ombudsman wrote to the regulator about banks rejecting the temporary identity certificate issued to foreigners. If a bank cannot verify a customer, the Act forbids it from opening the account (art. 41), so arguing at the counter changes nothing. Before the visit we confirm that the bank will accept your particular document.
03Citizenship and the bank's risk assessment
The bank must record your citizenship (art. 36), and it sets the risk level of each customer itself, looking among other things at the line of business and country risk - that is how the regulator describes it. The AML Act lists the warning signs: cash-heavy activity, an unusually complex ownership structure, links to high-risk countries or to countries under EU or UN sanctions (art. 43). The higher the assessed risk, the more detailed the questionnaire and the more documents the bank asks for. This check cannot be sidestepped. It can only be passed, with a complete file and answers that match the documents.
04Address and source of income
The bank has to understand why you need the account and, where justified, examine where the money comes from (art. 34 of the AML Act). In practice these are questionnaire items: where you work, who will pay into the account, what amounts you expect. An employment or service contract, a client agreement or a statement from your previous account backs the answers up. As for the address, the Act has the bank record it if known, yet without a correspondence address in Poland a bank may refuse even a basic payment account (art. 59ic of the Payment Services Act). We advise always bringing a lease or a registration certificate.
05Sp. z o.o.: the bank vets the people, not just the company
For a company the bank establishes the name, legal form, address, NIP and the details of its representatives, plus the beneficial owner and the ownership and control structure (arts. 34 and 36 of the AML Act). In its position on verifying corporate clients the regulator lists what a bank may rely on: a current KRS extract, the articles of association, NIP and REGON confirmations, and certificates from ZUS and the tax office. Where a shareholder is a foreign company, a certified extract from its home register is needed. Under joint representation every signatory is verified. A bank may not rely on the beneficial owner register (CRBR) alone and must note any discrepancies, so we file the CRBR entry before the bank visit.
06Three deadlines for a new S24 company
After the KRS entry the clocks run in parallel: 7 days to pay in the share capital in money and file the board's statement (arts. 158 and 167 of the Commercial Companies Code), 14 days for the CRBR filing, 21 days for NIP-8 with the account number. The first is the tightest: if the capital is to arrive by transfer, the account is needed within the first week. There is no basic account that a bank must open for a company, and no single deadline for handling a company's application. So we prepare the bank pack before the company is registered and book the visit for the first days after the entry.