Transferring money from abroad to buy a flat in Poland: source of funds, currency, AML

Transferring money from abroad to buy a flat is perfectly normal in Poland: you send the money to the developer's escrow account or to a notarial deposit, and the price is set in Polish złoty (PLN). However, every such purchase goes through an AML (anti-money laundering) check – the bank and the notary are required to establish who you are, who you are buying for and where the funds come from. Below we explain which documents you may need, how much SEPA and SWIFT transfers cost and how the euro exchange rate changes the price of a flat – using an example from our listings.

Key facts

• Banks and notaries are obliged institutions under the Anti-Money Laundering Act – they may ask about the source of your funds.
• The bank reports any transfer from abroad worth more than EUR 15,000 to the General Inspector of Financial Information – this is routine, not suspicion.
• A flat costing PLN 662,405 equals EUR 151,407 at the NBP average rate of 25 September 2026 (PLN 4.3750); a 5% change in the rate shifts this amount by about EUR 7–8 thousand.
• A euro transfer within the EU may not cost more than the corresponding domestic transfer – but this rule does not cover currency conversion.
• Cash of EUR 10,000 or more brought into or taken out of the EU must be declared at the border, together with information on its origin.

Where do you send a transfer from abroad to buy a flat?

When you buy from a developer, you pay into a residential escrow account (mieszkaniowy rachunek powierniczy). The developer agreement (umowa deweloperska) must state the bank, the account number and the amount, dates and method of payments (Article 35(1)(9) and (10) of the Developer Act). The price in the agreement and in developers' price lists is given in złoty, so it is the PLN amount that must reach the account – regardless of the currency in which you send the money. When you buy a completed flat for cash, part of the payment is sometimes settled through a notarial deposit (depozyt notarialny); we describe what such a schedule looks like in Buying a flat from a developer for cash (in Polish).

Funds in the escrow account are covered by the guarantees of the Bank Guarantee Fund (Bankowy Fundusz Gwarancyjny): the limit per depositor is the PLN equivalent of EUR 100,000, and any payout is made in złoty – the developer must include this information in the prospectus (annex to the Developer Act). How this protection works and what the Developer Guarantee Fund (Deweloperski Fundusz Gwarancyjny, DFG) is, we explain in Escrow account and the DFG (in Polish).

If you cannot come for the notarial deed (akt notarialny), an attorney can sign it for you – we describe the forms of power of attorney from abroad in our guide Buying property in Poland from abroad. Take the account number only from the agreement signed at the notary. If someone "changes the account number" in an email, first call the developer on the number from their website – fraud with a swapped account number targets exactly these large transfers.

AML at the notary and the bank – who checks what?

The Anti-Money Laundering and Counter-Terrorist Financing Act (consolidated text Dz.U. 2025 item 644) lists banks (Article 2(1)(1)) and notaries handling deeds transferring ownership of real estate (Article 2(1)(13)) among obliged institutions. Both apply so-called customer due diligence measures to you (Article 34(1)):

• they identify you and verify your identity – on the basis of your passport or another identity document;
• they establish the beneficial owner, i.e. the person on whose behalf the transaction is carried out;
• they assess the purpose and nature of the transaction;
• in justified cases, they examine the source of the assets (Article 34(1)(4)(b)).

For an occasional transaction, these measures apply from the equivalent of EUR 15,000 (Article 35(1)(2)(a)) – and buying a flat always exceeds this threshold. In addition, the bank reports to the GIIF (General Inspector of Financial Information) any transfer from abroad worth more than EUR 15,000 (Article 72(1)(2) and (2)) and any currency exchange above this threshold (Article 72(3)), and the notary reports any deed worth more than EUR 15,000 (Article 72(4)). These are automatic reports and do not mean that anyone suspects you of anything.

Important: if an institution cannot apply one of the measures – for example, it does not receive an explanation of where the money comes from – it will not carry out the transaction (Article 41(1)). In practice, this means a blocked transfer or a postponed notarial deed, so it is worth having your documents ready in advance.

Beneficial owner – are you buying for yourself or for someone else?

A beneficial owner is, among others, any natural person on whose behalf a transaction is carried out (Article 2(2)(1) of the AML Act). If parents abroad are paying for their child's flat, or you are buying through a company, the bank and the notary will want to know whose money it is and who will actually become the owner. For a company, the ownership structure is also established – the beneficial owner includes anyone holding more than 25% of shares or votes. The Act lists a transfer from a third party unrelated to the buyer as one of the higher-risk indicators (Article 43(2)(8)) – it is better to document it straight away, e.g. with a gift agreement.

When is the check more thorough?

Enhanced due diligence applies, among others, to politically exposed persons (PEPs), their family members and close associates – the institution must then establish the source of wealth and the source of funds (Article 46(2) and (6)), and it may also ask for a written statement on whether you are a PEP (Article 46(1)). The same applies to transactions linked to a high-risk third country on the European Commission's list (Article 44) and to other risk indicators, e.g. a transaction without the customer being physically present, where this risk has not been mitigated in another way (Article 43(2)(7)).

Source of funds – which documents should you prepare?

The Act does not contain a closed list of documents – each institution assesses the risk itself. Usually it is enough to show a logical "chain": how the money got into your account and how it reached Poland.

Source of funds	Example documents
Savings from employment	salary certificate or employment contract, tax return, bank statements covering several months
Sale of property abroad	sale agreement, confirmation that the price was credited to your account
Business activity	tax return, financial statements, dividend resolution
Gift from family	gift agreement, confirmation of the transfer from the donor, donor's bank statement
Inheritance	document confirming acquisition of the inheritance, transfer confirmation
Loan	loan agreement, confirmation of disbursement

It is best to have documents in a foreign language translated into Polish straight away. When you need a sworn translator and how much it costs, we explain in Sworn translator at a Polish notary.

A gift from close family also has tax consequences. The exemption from inheritance and gift tax for the "zero group" of closest relatives (grupa zerowa) requires you to report the acquisition within 6 months, and a cash gift above the tax-free amount must be documented by a transfer to the recipient's bank account or a postal money order (Article 4a(1) of the Inheritance and Gift Tax Act). Cash brought in a suitcase does not meet this condition. More on taxes for buyers from abroad in Taxes when buying property in Poland.

Buying a flat in Warsaw or Wrocław from abroad? We will help you choose a flat and guide the purchase through to the notarial deed – usually no commission for the buyer, because our fee is normally paid by the developer.

Buying a flat with euros – how much will you really pay?

The price is in złoty, so you bear the exchange rate risk. Take a 2-room flat (living room + 1 bedroom) for PLN 662,405 – the median price of 2-room apartments in Wrocław according to TM Invest listings data as of 27 September 2026 (738 available apartments). The NBP average euro rate on 25 September 2026 was PLN 4.3750.

Scenario	EUR/PLN rate	Amount needed in euros	Difference vs the rate of 25 September 2026
NBP average rate of 25 September 2026	4.3750	EUR 151,407	–
Złoty 5% stronger	4.1563	EUR 159,376	+EUR 7,969
Złoty 5% weaker	4.5938	EUR 144,197	−EUR 7,210
Lowest rate in the last 12 months (28 January 2026)	4.2009	EUR 157,682	+EUR 6,275
NBP złoty selling rate (table C, 25 September 2026)	4.3295	EUR 152,998	+EUR 1,591

The table leads to two conclusions. First, over the past year the euro rate fluctuated between PLN 4.2009 and PLN 4.3900 – a difference of about EUR 6.8 thousand on the same flat. Second, the spread alone, i.e. the difference between the average rate and the rate at which the bank buys euros from you, can cost more than EUR 1.5 thousand. Table C shows NBP rates; your bank uses its own, usually less favourable ones, so compare offers from several institutions before making the transfer.

For Warsaw the calculation is similar: the median price of a 2-room apartment in our listings is PLN 755,824, i.e. about EUR 172,760 at the rate of 25 September 2026. You can check current prices in our catalogues of apartments in Wrocław and apartments in Warsaw.

Currency conversion when paying into the escrow account in instalments

For a flat under construction, you pay in several instalments, according to construction progress (Article 8 of the Developer Act). Each instalment is converted at the rate on the day of the exchange, so you will know the total price in euros only after the last payment. Some buyers open a złoty account with a Polish bank and exchange euros gradually, when the rate suits them, and then transfer złoty to the escrow account. The history of such an account also makes the AML check easier. How to open an account in Poland and whether you need a PESEL (Polish national identification number) or NIP (tax identification number), see our checklist for foreigners.

How much does a SEPA or SWIFT transfer cost?

If you send euros from an EU country, Regulation (EU) 2021/1230 applies. The charge for a cross-border payment in euros must be the same as for a corresponding domestic payment of the same value (Article 3(1)). This rule does not apply to currency conversion charges (Article 3(4)). However, for a transfer initiated online, the bank must show you the estimated conversion cost and the amount the recipient will receive before sending it (Article 5).

Transfers from outside the EU (e.g. from the United Kingdom, the USA or Ukraine) usually go via SWIFT. Their cost depends on the tariffs of your bank, intermediary banks and the recipient's bank, and with the "SHA" or "BEN" charge option part of the fees may be deducted from the amount sent. So when paying into the escrow account, choose the "OUR" option if your bank offers it, or transfer a small surplus – even a small shortfall means the instalment has not been paid in full.

The Foreign Exchange Act (Prawo dewizowe) requires transfers abroad and domestic settlements related to foreign exchange transactions above the equivalent of EUR 15,000 to go through a bank or a payment institution (Article 25(1)). The takeaway for buyers: large amounts – by bank transfer only.

Cash, limits and sanctions

Carrying cash is not a good way to pay for a flat. Anyone entering or leaving the EU with cash worth at least EUR 10,000 must submit a declaration – with the owner's details, the origin of the funds and their intended use (Article 3 of Regulation (EU) 2018/1672). A transfer from an account in your country of residence is simpler and in itself documents the origin of the funds.

EU sanctions are a separate issue. For example, Regulation 765/2006 prohibits accepting deposits exceeding EUR 100,000 from Belarusian nationals and residents of Belarus (Article 1u), while providing for exceptions. Russian and Belarusian citizens should therefore check the bank's requirements before making a reservation – details in Mortgage and buying a flat in Poland for Belarusians.

If you are a Polish tax resident, also remember that income not covered by disclosed sources is taxed at 75% (Article 25e of the Personal Income Tax Act). A documented source of funds therefore protects you not only from the bank's questions, but also from a possible dispute with the tax office. The general rules for foreigners buying property, including when an MSWiA permit (from the Ministry of the Interior and Administration) is required, are in our guide Buying an apartment in Poland as a foreigner.

Frequently asked questions

Summary

Transferring money from abroad to buy a flat is above all a matter of good preparation: documents showing the source of funds, clear information on who the beneficial owner is, and a currency exchange plan. The price is in złoty, so on a flat costing PLN 662 thousand every percentage point of the euro rate is worth about EUR 1.5 thousand. What usually costs the most is not the transfer itself, but the currency conversion.

Living abroad and looking for a flat in Warsaw or Wrocław? Get in touch – we will select offers, discuss terms with the developer and guide you through the purchase up to the notarial deed. Usually no commission – our fee is normally paid by the developer. We have been on the market since 2016.

Legal status as of September 2026. Exchange rate calculations are indicative and based on NBP rates – your bank applies its own rates and fees. Document requirements are set by each institution individually. This article does not constitute legal or tax advice.

Sources

• Anti-Money Laundering and Counter-Terrorist Financing Act (Ustawa o przeciwdziałaniu praniu pieniędzy oraz finansowaniu terroryzmu) – consolidated text Dz.U. 2025 item 644 (Articles 2, 34, 35, 41, 43, 44, 46, 72)
• Act on the Protection of the Rights of Buyers of a Residential Unit or Single-Family House and on the DFG (Developer Act) – consolidated text Dz.U. 2026 item 880 (Articles 8, 35, annex – information prospectus)
• Foreign Exchange Act (Prawo dewizowe) – consolidated text Dz.U. 2024 item 1131 (Article 25)
• Inheritance and Gift Tax Act (Ustawa o podatku od spadków i darowizn) – consolidated text Dz.U. 2026 item 478 (Article 4a)
• Personal Income Tax Act (Ustawa o podatku dochodowym od osób fizycznych) – consolidated text Dz.U. 2026 item 592 (Article 25e)
• Payment Services Act (Ustawa o usługach płatniczych) – consolidated text Dz.U. 2026 item 623 (Article 54)
• Regulation (EU) 2021/1230 on cross-border payments in the Union (Articles 3, 5)
• Regulation (EU) 2018/1672 on controls on cash entering or leaving the Union (Article 3)
• Council Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus – consolidated version (Article 1u)
• NBP – average EUR rate, table A no. 187/A/NBP/2026 of 25 September 2026 and table C no. 187/C/NBP/2026
• Apartment prices: TM Invest developments catalogue, as of 27 September 2026