Rules
Bank account blocked in Poland: who can block it, for how long and how to unblock it
A blocked bank account in Poland is not one event with one deadline. A bank acting on its own suspicion may block funds for 72 hours at most, and only up to the amount it suspects. The General Inspector of Financial Information has 96 hours, and before its demand an institution may hold a transaction for no more than 24. Only a prosecutor can hold money for long — up to 6 months, extendable by another 6 — and a prosecutor's order can be appealed to a court. But there is a fourth case where none of these deadlines applies, because the law sets none: when the bank asks for documents. Here: the text of the rules, every deadline in one table, and what a bank is allowed to tell you if you ask.
Checked against Poland: residence, property and daily life for people already living there
Jurisdictions Poland
Contents
- Which of four reasons applies to your account
- A block by the bank itself lasts no more than 72 hours
- A block at the demand of the General Inspector: 24 and 96 hours
- A block by a prosecutor: up to 6 months, extendable by another 6
- Appealing a bank account block: against what, and where
- When a block on an account lapses by itself
- Does the bank have to tell you why it blocked your account
- A block with no deadline at all: when the bank asks for documents
- Bank account blocked after a residence card expired: which document is enough
- Who is liable for loss caused by an unjustified block
- How to unblock a bank account: the order of steps
- Common mistakes with a blocked bank account
- How to check this yourself
- Frequently asked questions about a blocked bank account in Poland
- When a blocked account is not a simple case
Money on an account stops being available for several quite different reasons, and from the outside they look the same. The deadlines, the authorities and the remedies differ in each, so the first thing to establish is which one you are facing. The second thing worth knowing straight away: in three of the cases the law names a specific number of hours, and in one it names none.
In Polish a block on an account is *blokada rachunku*, colloquially *blokada konta*. That is the phrase you will see in the bank's letters.
Which of four reasons applies to your account
| What you see | What it most likely is | Deadline in law |
|---|---|---|
| One transfer does not go through, or part of the funds is blocked; the bank mentions a review | A block by the bank or at the demand of the General Inspector | 72 hours, or 24 and 96 hours — this page |
| The bank asks for documents, a statement on the source of funds or updated details, and executes nothing until then | Inability to apply customer due diligence | no deadline in law — this page |
| Money is taken off the account, a letter comes from a bailiff or an authority, the balance drops to a certain level and stops | A seizure, not a block | bailiff seized my bank account |
| The whole company account is blocked, most often by the tax authority | A block on a qualified entity's account (STIR) | 72 hours and up to 3 months — tax authority blocked the account |
The difference between the first and the third row is fundamental. A block keeps the money in place; a seizure takes it. In a block the funds are still yours and have been passed to no one; in a seizure they go to the creditor, and what protects you is the protected amount. If the balance fell and the money went somewhere, this is not the page for you.
A block by the bank itself lasts no more than 72 hours
The basis is article 106a of the Banking Law (*Prawo bankowe*). Where a bank forms a justified suspicion that funds on an account derive in whole or in part from, or are connected with, a fiscal offence or an offence other than money laundering and terrorist financing, the bank is entitled to block the funds on that account (para. 3).
The rule carries two limits worth knowing, because people assume a block covers the whole account and lasts until the bank finishes looking.
Only the amount under suspicion may be blocked. The act says so directly: exclusively up to the funds on the account in respect of which the suspicion arises (para. 3, second sentence). If one 3,000 zł transfer is suspect and the account holds 20,000 zł, the rule gives no basis for holding the whole.
A block made by the bank may not last longer than 72 hours (para. 4). It is a hard limit and runs whether or not the bank has finished its review. Immediately after blocking, the bank notifies the prosecutor (para. 5), and within the same period the prosecutor issues an order opening or refusing to open proceedings and notifies the bank at once (para. 6).
What happens after 72 hours depends only on the prosecutor. If proceedings are opened, the prosecutor may block the funds by order for a fixed period — see below. If not, the basis for the block is gone.
A block at the demand of the General Inspector: 24 and 96 hours
The second route runs through the anti-money-laundering act (source) and concerns a suspicion of money laundering or terrorist financing. Here the bank does not decide alone — it notifies the General Inspector of Financial Information, GIIF (art. 86(1)), which confirms receipt of the notice with an official acknowledgement stating the date and time (para. 3). That time is the point every later deadline runs from.
The institution holds the transaction for no more than 24 hours from the acknowledgement — until it receives GIIF's demand or a release from the obligation, but no longer (para. 4). During that time it carries out neither the suspect transaction nor any other transaction debiting the account where those funds sit.
GIIF may demand that the account be blocked for no more than 96 hours, counted from the date and time in the acknowledgement (para. 5). The demand names the assets it covers, and the institution executes it at once. Immediately afterwards GIIF notifies the prosecutor (para. 8).
GIIF can also act without a prior notice from the bank: article 87 lets it send an institution a demand to hold a transaction or block an account on its own initiative, and the 96 hours then run from the moment the demand is received (art. 87(2)).
There is a third possibility worth knowing, because it ends matters fastest: GIIF may release the institution from the obligation to hold the transaction (art. 86(6)) if the information it has gives no grounds to notify a prosecutor, or if it considers that a block would hamper the work of law enforcement.
A block by a prosecutor: up to 6 months, extendable by another 6
Only a prosecutor can hold money for long, and both acts set it up the same way.
After a notice from GIIF, a prosecutor may by order hold a transaction or block an account for a fixed period of no more than 6 months from the day the notice was received (art. 86(9)); the order may also be issued without such a notice (para. 10). The Banking Law says the same: after proceedings are opened, a block for a fixed period of up to 6 months from receipt of the bank's notice (art. 106a(6)), and where money laundering is suspected the prosecutor may block an account for up to 6 months even without a notice from the bank (para. 3a).
The prosecutor may extend the block for a further fixed period of no more than another 6 months (art. 86(11a); art. 106a(7a)). In practice the upper bound of this route is a year, not half a year.
The order states the scope, manner and period of the block (art. 86(11); art. 106a(3a) and (6)). That matters: an order without a fixed period does not meet these rules.
Appealing a bank account block: against what, and where
A prosecutor's order can be appealed to the court competent to hear the case — the same in both acts (art. 86(11), second sentence; art. 106a(7)). The same rules apply to an extension, so an extension can be appealed too (art. 86(11a); art. 106a(7a)).
It matters what these two acts do not provide. They provide an appeal only against the prosecutor's order. For the bank's 72-hour block, the 24-hour hold and GIIF's 96-hour demand, these acts set out no separate remedy. Those three expire on their own when time runs out, so the defence there is to watch whether the deadline has passed, not to file a document.
Matters not covered by the act are governed by the Code of Criminal Procedure (art. 106a(9)). We have not read that code at source, so we do not give a deadline for filing an appeal or how it is counted — check it there or with a representative.
When a block on an account lapses by itself
Both acts contain the same clause, and for the account holder it matters most after the deadlines. A hold on a transaction or a block on an account lapses if, before its period expires, no order securing assets or order concerning physical evidence has been issued (art. 86(13); art. 106a(8)).
So a block does not turn into something permanent on its own. Either one of those two orders appears while it runs, or the basis disappears when the period ends. If the period has passed and the bank still executes nothing, the question for the bank is not "why is my account blocked" but "under which order does the block continue after its period".
Does the bank have to tell you why it blocked your account
This is a rule almost nobody knows, and it changes the conversation with the bank.
The general rule is confidentiality: institutions do not tell a client that they have passed information to GIIF. But art. 86(12) provides that an institution may, at the client's request, inform the client that GIIF has sent a demand to block — and adds expressly that in that case article 54 of the act, the non-disclosure rule, does not apply. The same holds for a GIIF demand made without a notice from the bank, because art. 87(4) applies art. 86(9)–(13) accordingly.
Read it precisely, because it is easy to overshoot the other way. The rule says "may inform", not "informs" — it is the institution's power, not your entitlement, and the bank is not obliged to answer. And it covers only the fact that GIIF sent a demand, not the reasons, not the content of the notice and not a prosecutor's order.
The practical point is still real: information about a block demanded by GIIF is not confidential once the client asks for it. A bank that refuses to say anything at all because it is "not allowed to tell you anything" is relying on a rule this very provision makes an exception to. Make the request in writing, so that a refusal is in writing too.
A block with no deadline at all: when the bank asks for documents
This is a common case and the only one where no number of hours applies — because the law sets none for it.
Customer due diligence measures are identifying the client and verifying their identity, identifying the beneficial owner, assessing the business relationship and obtaining information on its purpose, and ongoing monitoring of the relationship, including analysis of transactions (art. 34(1)). If an institution cannot apply one of them, art. 41(1) requires it not to enter into a business relationship, not to carry out an occasional transaction, not to carry out transactions through the bank account, or to end the relationship.
This is not a block within the meaning of art. 106a or art. 86. No one notifies a prosecutor, no 72 or 96 hours run, and there is no order to appeal. The institution separately assesses whether its inability to apply these measures is grounds to notify GIIF (art. 41(2)) — so one can turn into the other, but not by itself.
That is why this state can last for weeks, and it ends only when the cause is removed. If the bank executes nothing because it lacks a valid identity document, a statement on the source of funds or information on the real nature of your business, the way out is not an appeal and not waiting for a deadline. It is supplying what is missing — and that is the first thing to establish before you start counting hours.
Bank account blocked after a residence card expired: which document is enough
This is a specific case of the block with no deadline. The bank must ensure that the customer's documents and data are kept up to date (art. 34(1)(4)(c) of the anti-money-laundering act), and among the identification data it keeps the series and number of the identity document (art. 36(1)(1)(d)). When the residence card (karta pobytu) whose number sits in the bank's system expires, the bank sees an out-of-date document and asks for an update — and until then, under art. 41, it may refuse to carry out transactions.
The act does not require a valid residence card for this. Art. 37(1) allows identity to be verified on the basis of an identity document or other documents, data or information from a reliable and independent source. A passport is an identity document. If the bank insists on the residence card specifically, that is its internal risk policy, not a statutory requirement — and it is worth asking it in writing which document it expects and on what basis.
Two situations where an expired date on the card does not mean unlawful stay, and the bank may not know it:
- A citizen of Ukraine whose card was due to expire on or after 24 February 2022: the card is valid by operation of law until 4 March 2027 (art. 42 of the act on assistance to citizens of Ukraine). The card still shows the old date, so the bank has to be pointed to the provision — details in the article on the temporary residence permit.
- An application for the next permit filed on time: the stay is lawful until the decision becomes final (art. 108 of the Act on Foreigners), and the free certificate (zaświadczenie) of filing from MOS confirms it — how it works.
In both cases you go to the bank with your passport and a document confirming lawful stay: a reference to art. 42 or the MOS certificate. Waiting achieves nothing, because under art. 41 no deadline runs.
Who is liable for loss caused by an unjustified block
Art. 106a(10) splits liability in a way worth knowing in advance. The bank is not liable for loss that may result from performing its duties under paras. 3–5 in good faith. But if the circumstances that led to the block had no connection with a crime or with concealing criminal activity, liability for the loss caused by the block lies with the State Treasury (*Skarb Państwa*).
Put plainly: where a block rested on a suspicion that was not borne out, the claim for loss is addressed not to a bank acting in good faith but to the State Treasury. The rule states no procedure or deadline for such a claim, and we have not read those rules at source, so we do not give them here.
How to unblock a bank account: the order of steps
- Work out whether it is a block or a seizure. If money was taken off the account rather than held on it, it is a seizure, and what applies is the amount protected from a bailiff, not the deadlines on this page.
- Work out whether the bank is waiting for documents. It is a common case and the only one with no deadline. If the bank is asking you to update your details or provide a statement on the source of funds, no clock is running, and the only way out is to supply the documents.
- Ask for the date and time. For a block under art. 106a, 72 hours run from when it was imposed; on the GIIF route, 24 and 96 hours run from the acknowledgement of the notice. Without the date and time you cannot tell whether the deadline has passed.
- Make a written request for information about the block. Art. 86(12) lets the institution tell a client, on request, about a GIIF demand, and confidentiality does not stand in the way. A written refusal is a result too.
- Check whether there is a prosecutor's order and what period it states. If there is, it can be appealed to the court competent to hear the case. If there is not and the hour-based deadlines have passed, the block has no basis.
- Watch the date on which the block lapses. Without an order securing assets or concerning physical evidence, the block lapses when its period ends.
Common mistakes with a blocked bank account
| Mistake | Why it hurts |
|---|---|
| Waiting for 72 hours to pass when the bank is waiting for documents | Under art. 41 no deadline runs — waiting leads nowhere |
| Assuming the bank may not tell you anything | Art. 86(12) lifts confidentiality when the client asks |
| Appealing against the bank's block or GIIF's demand | These acts provide an appeal only against a prosecutor's order |
| Assuming the block covers the whole account | Art. 106a(3): only up to the amount under suspicion |
| Moving funds to another account while things are being clarified | The institution monitors the relationship on an ongoing basis under art. 34(1) point 4 |
| Confusing a block with a seizure | Different authorities, deadlines and remedies — see the table at the top |
How to check this yourself
- Act of 29 August 1997 — Banking Law, consolidated text Dz.U. 2026 poz. 38 (announcement of the Marshal of the Sejm of 10 December 2025), art. 106a(3)–(10) — block by the bank, 72 hours, the prosecutor's order, appeal, lapse of the block and the State Treasury's liability.
- Act of 1 March 2018 on counteracting money laundering and terrorist financing, consolidated text Dz.U. 2025 poz. 644 — art. 34(1) (customer due diligence measures, including keeping documents up to date), art. 36(1)(1)(d) and art. 37(1) (identity document and verification on other reliable documents), art. 41 (consequences of being unable to apply them), art. 86 (24 and 96 hours, prosecutor, appeal, para. 12 on informing the client, lapse of the block) and art. 87 (GIIF demand without a notice).
- Act on Foreigners (art. 108) and the act on assistance to citizens of Ukraine (art. 42) — lawful stay with an expired card; covered at source in the article on the temporary residence permit.
- Code of Criminal Procedure — governs matters not covered, including the appeal procedure. We have not read this act at source.
Frequently asked questions about a blocked bank account in Poland
How long can a bank account block last in Poland?
It depends on who imposed it. A bank on its own suspicion — no more than 72 hours. An institution before a GIIF demand — no more than 24 hours. A GIIF demand — no more than 96 hours. A prosecutor — up to 6 months, extendable by another 6. If the bank is waiting for documents under art. 41 of the anti-money-laundering act, the law sets no deadline at all.
Can a bank block the whole account?
Under art. 106a(3) of the Banking Law — no. The rule allows a block only up to the funds in respect of which there is a justified suspicion. A GIIF demand also names the assets it covers.
Does the bank have to tell me why it blocked my account?
It has no such duty, but art. 86(12) of the anti-money-laundering act lets an institution, at the client's request, say that GIIF has demanded a block, and in that respect lifts the non-disclosure rule in art. 54 of that act. It is the bank's power, not the client's right — but saying the bank may tell you nothing is inaccurate.
How do I unblock a bank account?
First establish the basis. If the bank is waiting for documents or a statement on the source of funds, supplying them ends the block, and no deadline runs. If it is a block under art. 106a or a GIIF demand, hour-based deadlines apply and the basis disappears after them. If there is a prosecutor's order, the route is an appeal to the court competent to hear the case.
Can a bank account block be appealed?
A prosecutor's order on a block — yes, to the court competent to hear the case, and the same for an extension. For the bank's 72-hour block, the 24-hour hold and GIIF's 96-hour demand, these acts give no separate remedy; they expire with time.
What happens when the block period ends?
The block lapses if, before its period expires, no order securing assets or order concerning physical evidence has been issued. It does not become permanent by itself.
The bank blocked a transfer but the account works. What is that?
Most likely a hold on a specific transaction rather than a block on the account. The anti-money-laundering act treats the two separately and gives both the same deadlines — 24 hours until a GIIF demand and 96 hours for the demand itself.
My bank blocked my account because my residence card expired. What should I do?
The anti-money-laundering act allows identity to be verified with an identity document or other reliable documents, so a passport is enough for identification; the act does not require a valid residence card. For citizens of Ukraine, cards expiring from 24 February 2022 were extended by law until 4 March 2027. If an application for the next permit was filed on time, the stay is lawful until a final decision, and the MOS certificate confirms it. Take these documents to the bank — no deadline will run out on its own.
Who is liable if the block was unjustified?
The bank is not liable for loss from performing its duties under art. 106a(3)–(5) of the Banking Law in good faith. If the circumstances that led to the block had no connection with a crime, the State Treasury is liable for the loss.
How is a block different from a bailiff seizure?
A block keeps the money on the account and passes it to no one; a seizure passes it towards a debt and protects only the protected amount. Different authorities, grounds, deadlines and remedies.
Does a block apply to a business account?
The block rules in art. 106a of the Banking Law and art. 86 of the anti-money-laundering act speak of an account without excluding business accounts. A separate matter is the block on a qualified entity's account by the tax authorities, which has its own rules and deadlines; see [tax authority blocked the account](entry:poland-stir-block).
When a blocked account is not a simple case
You can handle it yourself when it is clear which mechanism you are facing and what remains is to watch the deadline or supply documents. It is different when:
- the deadline has passed and the bank still executes nothing and gives no basis;
- there is a prosecutor's order and an appeal has to be filed;
- a business account is blocked and payments to employees have stopped;
- the bank asks for documents you do not have or will not accept the ones you give;
- a bailiff's seizure arrived at the same time as the block — two separate matters at once.
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