The Polish Notarial Deed: What Foreign Property Buyers Need to Know
This guide is general legal information, not legal advice. How the rules apply depends on your individual circumstances, contracts, documents and deadlines. If you need advice or representation, the matter should be assessed by a qualified Polish lawyer. Twoja Sprawa helps you organise the documents for that assessment.
Key points
- The notarial deed (akt notarialny) is the only valid way to transfer ownership of real estate in Poland — a contract in any other form is void by operation of law.
- A Polish notary (notariusz) is not the same profession as a UK notary public — the Polish notary is a public office holder with far broader duties: they collect and remit transaction tax themselves and file the land register application on the buyer's behalf.
- If you don't speak Polish, a sworn translator is mandatory at the signing — the notary cannot waive this unless they personally document fluency in your language.
- You can sign through a power of attorney — you don't have to attend the notary's office in Poland in person if you arrange a notarial power of attorney beforehand.
- The notary can hold the purchase price in a notarial escrow (depozyt notarialny) as a settlement safeguard — the exact banking mechanics need to be confirmed with the specific notary.
- The notarial deed itself does not grant any right of residence in Poland — that is governed separately by immigration rules.
Who this guide is for
- UK residents (British nationals or foreign partners of Polish returnees) buying an apartment or house in Poland and dealing with a Polish notary for the first time.
- Poles who moved to the UK and are returning to buy property, and want to understand how the Polish notarial process differs from what they may remember or from UK conveyancing.
- Buyers planning to sign through a power of attorney, without travelling to Poland for the signing itself.
- This guide is not about the Ministry of Interior permit procedure for foreign buyers (covered separately, linked below), nor about taxes and notary fees in detail — those are covered in other guides in this hub.
Contents
- What the notarial deed is and why it's mandatory
- Polish notary vs UK notary public — the key differences
- Step by step: what happens at the signing
- Sworn translators — when they're mandatory
- Notarial escrow as a settlement safeguard
- Documents you will need
- Common risks and mistakes
- Checklist
- Frequently asked questions
- Deadlines
What the notarial deed is and why it's mandatory
Under the Polish Civil Code, both the contract obliging a party to transfer ownership of real estate and the contract actually transferring that ownership must be made in the form of a notarial deed, on pain of nullity. This applies to a preliminary contract (if it is meant to allow the buyer to sue for completion in court), a resale purchase contract, and a developer's contract on the primary market alike.
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Request a free initial assessmentIn practice this means: no contract signed "on paper," by email, or even with a simply notarised signature transfers ownership of real estate in Poland. The only route is a notarial deed drawn up by a Polish notary. This rule applies identically to Polish citizens and to foreign buyers — the differences appear in the notary's extra duties toward a party who doesn't speak Polish, and in the possible requirement for a Ministry of Interior permit for a foreign buyer (covered in Buying Property in Poland Remotely from the UK).
Polish notary vs UK notary public — the key differences
This is one of the most common sources of confusion for UK-based buyers. In England and Wales, a notary public is typically a lawyer performing a narrow, additional certification function — most property transactions are run by a solicitor or licensed conveyancer, and a notary public mainly appears for documents destined for use abroad.
In Poland, the notariusz plays a much broader role:
| Feature | Polish notary (notariusz) | UK notary public |
|---|---|---|
| Status | Public office holder, though operating a private practice (not a civil servant) | Lawyer with an additional certification licence |
| Who runs the property transaction | The notary drafts and executes the deed transferring ownership themselves — the transaction cannot happen without them | A solicitor or conveyancer usually runs the whole transaction (conveyancing); the notary public mainly certifies documents for overseas use |
| Taxes | On a resale purchase, the notary collects the civil law transactions tax (PCC, roughly equivalent to Stamp Duty Land Tax) as a matter of law and remits it to the tax office | Not involved in transaction taxes |
| Land register filing | On a developer's contract, the notary must automatically file the buyer's claim with the land and mortgage register (księga wieczysta, broadly analogous to the HM Land Registry title register) | Registration with HM Land Registry is a separate step, usually handled by a solicitor |
| Liability | The notary carries professional and financial liability for the correctness of the notarial act | Liability governed separately by UK professional rules |
The practical takeaway: if in the UK you only ever used a notary public to certify a single document (say, a power of attorney for use abroad), don't map that experience directly onto a Polish transaction. In Poland it is the notary — not a separate lawyer running the deal — who is the central figure at completion. An estate agent or a lawyer advising a party is optional and additional in Poland, but the notary's presence at the deed itself is always mandatory.
A separate point worth understanding upfront, if you plan to act through a power of attorney, is that a Polish notary is not the same as a Polish consul in the UK. A consul can certify a signature or issue a copy of a document, but drawing up a full notarial deed (e.g. a power of attorney in notarial form) requires special authorisation from the Minister of Justice, and in practice is not a standard, readily available consular service. For how to prepare a power of attorney from the UK (notary public plus apostille), see Buying Property in Poland Remotely from the UK.
Step by step: what happens at the signing
- Draft preparation. The notary (usually based on data and documents provided by the parties) prepares a draft deed before the signing date. Ask to review the draft in advance, especially if a translator will be involved — this shortens the actual signing appointment.
- Identity and document checks. The notary verifies the parties' identity (ID card or passport), the legal status of the property (including the land and mortgage register), and — as of recent rules — whether a party's PESEL number appears on the register of restricted PESEL numbers; if it does, the notary must refuse to carry out the transaction.
- Reading the deed aloud. The notary reads out the full text of the deed in the presence of all parties (and the sworn translator, if a party does not speak Polish — see below).
- Questions and clarifications. This is the point to ask questions — once signed, the deed binds the parties on its stated terms.
- Signing. The deed is signed by all parties (in person, or through an attorney acting under a notarial power of attorney) and by the notary.
- Certified copies and next steps. The notary issues certified copies of the deed to the parties. On a developer's contract, the notary must automatically file the buyer's claim with the land register through the courts' electronic system. On a resale purchase, the notary typically also files the application to register the new owner, though the exact scope of this duty and the related court fees should be confirmed with the specific notary.
Notarial acts are performed in Polish. If you want the deed drawn up in parallel in English, the notary — at your request — may perform the act additionally in a foreign language, using their own documented fluency or the help of a sworn translator.
Sworn translators — when they're mandatory
This is one of the points that most often surprises UK-based buyers. If a party to the notarial act does not speak Polish, and no translation into a language they understand is attached to the act, the notary is obliged to translate the deed either personally (if they are documented as sufficiently fluent in that language) or with the help of a sworn translator (tłumacz przysięgły). In practice, for transactions involving UK nationals who don't speak Polish, having a sworn translator present is the standard — it is not a formality that can be waived "by agreement of the parties."
What this means in practice:
- You need to arrange a sworn translator in advance for the signing appointment — this cannot realistically be improvised on the day if the translator has no prior slot booked.
- The cost of the translator is usually borne by the party who needs one (though the parties can agree otherwise) — ask the notary about the customary practice at their office and the expected cost well ahead of time.
- The sworn translator must be listed with the Ministry of Justice. The Ministry of Justice maintains a nationwide, publicly searchable register of sworn translators by language and location — you can use it from the UK while planning your trip or a remote signing.
- Alternative: the notary's own language skills. If the notary documents their own fluency in your language, they may perform the act without a translator — in practice this is less common and needs to be confirmed directly with the office beforehand.
- The sworn translator carries professional liability for the accuracy of the translation — their details, including their licence number, are recorded with the deed.
If you act through a power of attorney and are not personally present at the signing, the duty to provide a translator applies to your attorney (if they don't speak Polish) — not to you as the absent principal.
Notarial escrow as a settlement safeguard
On resale transactions — especially where the parties don't know each other and there is no additional safeguard such as a mortgage paid out directly to the seller — the notary may hold money (in Polish złoty or a foreign currency) on deposit in connection with the notarial act, for release to a specified person once agreed conditions are met. This is the depozyt notarialny, or notarial escrow.
In practice, notarial escrow is often used precisely to secure payment of the price: the buyer pays the price into escrow, and the notary releases it to the seller only once the conditions set out in the protocol are met — for example, once the buyer's ownership has been finally registered in the land register, or once a prior owner's mortgage charge has been removed. It's worth knowing, though, that notarial escrow is not the same thing as a bank escrow account familiar from UK practice — it is a separate mechanism regulated by the Polish Law on the Notarial Profession, based on a bank account operated by the notary for escrow purposes. The banking and accounting details of this mechanism, including how well the deposited funds are protected, should be confirmed directly with the notary's office handling your transaction.
If you're buying from the UK and planning a large wire transfer, it's worth asking the notary about notarial escrow — and its cost — as early as when you're setting a date for the signing. It can give you extra confidence, especially where part of the transaction is being handled remotely.
Documents you will need
The exact list depends on the type of transaction (resale vs. developer, cash vs. mortgage) and should be confirmed with the notary handling the deed, but typically includes:
- proof of identity (ID card or passport) for each party or their attorney,
- the land register (księga wieczysta) number of the property and, for a resale, the seller's title to it,
- a notarial power of attorney — if a party is acting through an attorney, plus an apostille and translation if it was drawn up abroad,
- a certificate showing no one is registered as resident at the address, and no outstanding service-charge arrears (for flats in housing cooperatives or owners' associations),
- documentation showing the source of the purchase funds — banks and notaries, as obliged entities, may require this under anti-money-laundering rules,
- for a foreign buyer outside the statutory exemptions — a Ministry of Interior permit to acquire real estate, or a promise of such a permit,
- for a purchase from a developer — the information prospectus and the handover protocol.
Common risks and mistakes
- Assuming the notary will "run the transaction" like a UK solicitor. The Polish notary is responsible for the correctness of the deed itself, not for strategic advice during negotiations or an assessment of whether the deal is a good one — that's the role of a separate lawyer you engage on your own behalf.
- Not booking a sworn translator in advance. Without a translator, the notary cannot carry out the act with a party who doesn't speak Polish (unless the notary is personally fluent) — failing to book usually means the signing date has to be postponed.
- Signing without genuinely understanding the deed. The notary reading the deed aloud in Polish, even with oral interpretation, is not the same as calmly reading a draft in advance — ask for the draft and a written translation ahead of time.
- Leaving AML documentation until the last minute. Bank statements, documents from the sale of a previous property, or a gift deed in English are usually sufficient, but gathering and possibly translating them takes time — build in a margin before your planned signing date.
- Overlooking the Ministry of Interior permit requirement for foreign buyers. If the buyer is not a Polish citizen and doesn't fall within any of the statutory exemptions, a deed signed without the required permit is void by operation of law.
- Not discussing notarial escrow with an unfamiliar counterparty. For larger sums without a mortgage-linked safeguard, ask the notary about this option early, not on the day of signing.
If your situation differs from the scenarios above — for example, you're coordinating the deed with selling a UK property, or you're unsure about the Ministry of Interior permit — you can request a free initial assessment before you book a date with the notary.
Checklist
- [ ] You've agreed the language of the act with the notary and clarified whether a sworn translator is needed.
- [ ] You've booked a sworn translator from the Ministry of Justice register for the signing date.
- [ ] You've received the draft deed for advance review (ideally with a translation).
- [ ] You've gathered documentation showing the source of your purchase funds.
- [ ] You've checked whether, as a foreign buyer, you need a Ministry of Interior permit (or qualify for an exemption, e.g. a self-contained residential unit).
- [ ] If acting through an attorney — the power of attorney is in notarial form and (if drawn up abroad) carries an apostille and translation.
- [ ] You've asked the notary about the availability and cost of notarial escrow as a settlement safeguard.
- [ ] You know the approximate cost of the sworn translator and the notary's fee before the signing date.
Frequently asked questions
Can I sign a notarial deed in Poland without speaking Polish? Yes, but the notary must then arrange translation — either personally, if they are fluent in your language, or with the help of a sworn translator. Without this safeguard, the notary should not carry out the act with a party who doesn't speak Polish, since that would undermine your right to understand what you're signing.
Does the sworn translator have to be physically present, or is a written translation enough? Practice can vary between notary offices, but the general rule is that the translator is present while the deed is read out and signed, rather than the notary simply relying on a written translation prepared in advance.
Is a Polish notary the same as a UK solicitor handling conveyancing? No. The Polish notary focuses on the correctness of the notarial act itself, collecting the PCC tax, and filing the land register application. They do not advise strategically during negotiations and are not a substitute for an independent lawyer you can additionally engage to review the contract or the property's legal status.
Can I choose "my own" notary, or does the seller or developer decide? In practice, the choice of notary usually rests with the buyer, since on a resale the buyer customarily bears the notary's fee (on a developer's contract, the fee is split equally between developer and buyer under Article 6(2) of the Developer Act) — in practice, though, the parties often agree on this jointly, especially under time pressure.
What happens if the deed is signed without a required Ministry of Interior permit for a foreign buyer? Acquisition of real estate by a foreigner in breach of the Act on the Acquisition of Real Estate by Foreigners (without the required permit) is void by operation of law. The court rules on the nullity at the request of specified administrative authorities — this is a serious transaction risk that must be ruled out before signing, not after.
Is notarial escrow mandatory? No — it's an optional mechanism the parties may choose to use. It's particularly useful when there's no other settlement safeguard (for example, no mortgage paid out directly to the seller), and the parties want extra certainty about the sequence: payment first, land register entry second.
Can I sign through a power of attorney if I live in the UK and don't want to travel to Poland? Yes, provided you arrange a power of attorney in notarial form in advance — for how to prepare one from the UK (notary public, apostille, translation), see the guide on buying property remotely from the UK, linked below.
Deadlines
The notarial deed itself doesn't have a "limitation period" as a one-off act, but keep the related deadlines in mind:
- A Ministry of Interior permit to acquire real estate as a foreigner is valid for 2 years from the date it is issued — if the notarial deed isn't signed within that time, the permit lapses and the procedure has to be repeated.
- A promise of a Ministry of Interior permit is valid for 1 year from the date it is issued — during that time, the corresponding permit cannot be refused unless the factual circumstances of the case have changed.
- Claims under a preliminary contract become time-barred one year after the date on which the final contract was supposed to be concluded — relevant if a long time passes between the preliminary contract and the notarial deed.
Related guides
- Reservation Agreement or Preliminary Contract: What Should a Buyer Sign?
- Buying Property in Poland Remotely from the UK: Power of Attorney, Apostille and Translation
- Taxes, Notary Fees and Other Costs of Buying Property in Poland
- How to Buy Property in Poland: A Step-by-Step Guide for UK Buyers
Przeczytaj po polsku: Polski akt notarialny – co cudzoziemiec powinien wiedzieć przed zakupem
Sources
- Civil Code (Kodeks cywilny), consolidated text Dz.U. 2026 item 795 (Articles 99, 158, 389-396, 556-576) — Chancellery of the Sejm / ISAP — https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU19640160093
- Law on the Notarial Profession (Prawo o notariacie), consolidated text Dz.U. 2026 item 614 (Articles 2, 85a, 87, 92, 108) — Chancellery of the Sejm / ISAP — https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU19910220091
- Act of 24 March 1920 on the Acquisition of Real Estate by Foreigners, consolidated text Dz.U. 2017 item 2278 — Chancellery of the Sejm / ISAP — https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU19200310178
- Act of 20 May 2021 on the Protection of the Rights of Purchasers of a Residential Unit or Single-Family House and the Developer Guarantee Fund, consolidated text Dz.U. 2026 item 888 — Chancellery of the Sejm / ISAP — https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20210001177
- Act of 25 November 2004 on the Profession of Sworn Translator — ELI / Government Legislation Centre — https://eli.gov.pl/eli/DU/2004/2702/ogl
- Register of sworn translators — Ministry of Justice (Poland) — https://www.gov.pl/web/sprawiedliwosc/tlumacze-przysiegli2
- Act of 25 June 2015, Consular Law, consolidated text Dz.U. 2015 item 1274 (Article 28) — Chancellery of the Sejm / ISAP — https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20150001274
- Obtain a permit to acquire real estate, shares or stock as a foreigner — Ministry of Interior and Administration (Poland) — https://www.gov.pl/web/mswia/uzyskaj-zezwolenie-na-nabycie-nieruchomosci-akcji-udzialow-przez-cudzoziemcow
- Acquisition of real estate by a foreigner — Ministry of Economic Development and Technology (biznes.gov.pl) — https://www.biznes.gov.pl/pl/portal/ou209
Information verified on: 11 July 2026.