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Poland: GIIF changes reporting schemas for notarial activities and transactions

GIIF Notice No. 110 introduces new XSD reporting schemas — including real-estate data. In force 15 and 30 June 2026. AML Radar signal.

Detected: Updated: In force
Jurisdiction
🇵🇱 Poland
Authority
General Inspector of Financial Information (GIIF), Ministry of Finance
Instrument type
Notice / technical change to reporting schema (XSD)
In force from
15.06.2026 — 'GIIF-only' transaction schema from 15 June 2026; notarial activities (GIIF + Head of KAS) from 30 June 2026
For non-financial firms — possibly relevant

The change is technical and falls on notaries and entities reporting to GIIF; it imposes no new duty on a typical company. But adding real-estate fields (land register, plot identifier, floor area) shows how granularly the state monitors property-market transactions.

AML Radar — Poland, GIIF Notice No. 110, change to XSD schemas for reporting notarial activities and transactions

In brief

  • What: new XSD schemas for reporting to GIIF — notarial activities and transactions reported to GIIF only.
  • Who issues it: the General Inspector of Financial Information (GIIF), Ministry of Finance (Poland).
  • Status / timing: published; in force from 15 June 2026 (transactions reported to GIIF only) and from 30 June 2026 (notarial activities reported to GIIF and the Head of KAS).

What changes

GIIF (Notice No. 110) amends the XSD schemas used for reporting. The real-estate schema adds new fields: the land register number, a structured plot identifier, the number of rooms, the floor, the usable floor area and the built-up property area; for natural persons, a field for the country issuing the identity document is added. The “GIIF-only” transaction schema changes the format of the transaction identifier field. The legal basis is the Act of 17 October 2025 (Dz.U. 2025 item 1669); the schemas are registered in CRWDE under numbers 2026/04/28/14250 and 2026/04/30/14252.

Who is affected

Notaries and obliged entities reporting transactions to GIIF, as well as vendors of SI*GIIF reporting software.

What it means for non-financial firms

This is a technical change whose direct addressees are notaries and entities reporting to GIIF — it imposes no new obligation on a typical non-financial firm. It is worth noting for two reasons. First, it shows how granularly the state collects data on property-market transactions (down to the land register number and floor area) — relevant context for anyone in real estate. Second, it is a reminder that AML obligations in Poland do not end with banks. If you are unsure whether your firm falls under a sanction screening obligation, this is a good moment to check — and we cover the legal basis of sanctions packages here.

What’s next

After 15 and 30 June 2026, only the new schemas apply — reporting-software vendors must update their integrations. Full notice: GIIF Notice No. 110.

Legal basis and sources
GIIF Notice No. 110 — gov.pl
Disclaimer

AML Radar is an informational monitor, not legal advice. The content is based on publicly available government sources (links above) as of the update date. Facts and dates may change — verify the current status at the source before acting and consult a lawyer where needed.

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