Month: September 2026

When the REJA24 system was launched in 2020, hardly anyone anticipated that, within a few years, Poland would become one of the most popular flag states for recreational vessels in Europe. Today, the register already contains well over 100,000 vessels, and a significant proportion of the ship operators are from abroad. The Polish flag is no longer a solution used exclusively by domestic sailors. It has become a recognisable brand on waters around the world.  

It is no exaggeration to say that the 2018 Act has been one of the greatest successes of the Polish maritime administration in recent years. Whilst for decades the discussion centred primarily on ways to strengthen the Polish merchant flag, in practice it is the recreational flag that has begun to build Poland’s profile in marinas across the Mediterranean, the Atlantic and the North Sea. After all, every yacht flying the white-and-red flag is an ambassador for the country.  

Success, however, comes at a price.  

The scale of interest in the Polish flag has led to a situation where the legislator has concluded that the current registration model requires revision. Three main arguments recur in the justification for the draft amendment to the Act on the Registration of Yachts up to 24 metres in length currently under consideration:  

• a lack of up-to-date data on ship operators, 
• limited capacity to fulfil the obligations of the flag state, 
• a growing number of cases involving the use of vessels flying the Polish flag for criminal activities abroad.  

As a result, a draft amendment has been drawn up, which is currently being considered by parliament. This draft differs from the version originally proposed. During the consultation and legislative process, some of the proposals put forward by the yachting industry were considered. This does not alter the fact that the proposed reform represents the most significant change to the rules governing the Polish flag since the establishment of REJA24.  

The end of lifetime registration  

The public debate today focuses primarily on surveys and changes to fee levels. Paradoxically, however, the most far-reaching change may turn out to be something entirely different: a move away from the concept of a lifetime registration document.  

Until now, the Polish flag has operated under a very simple model. Provided the ship had been registered correctly, the document remained valid indefinitely. Of course, there was still an obligation to report certain changes, but the mere fact of holding the document did not require periodic renewal. It was precisely this simplicity that was one of the reasons for choosing the Polish register. The amendment departs from this idea almost entirely.  

Every five years, the owner will have to confirm the validity of the document and that the details held in the register are up to date. This does not mean that the vessel must be re-registered. The intention is for this to be an administrative procedure enabling the state to verify whether the vessel still exists, who owns it and whether the ship operator’s contact details remain up to date.  

In ideological terms, it is hard to deny that this solution is rational. A flag state should know who is sailing under its flag. The problem, however, lies elsewhere.  

Over the past few years, thousands of ship operators have made business and personal decisions based on the model of documents being valid indefinitely. For this group of ship operators, the amendment will not be a “clarification of administrative obligations”, but a change to the rules after they have already entered the system. This is where questions begin to arise about the limits of the legislator’s interference in existing legal relationships and the sphere of so-called “legitimate expectations”. There is no doubt that this debate will resurface in the future.  

Suspension of a document as an intermediate step  

One consequence of the new model is the possibility of suspending the validity of a registration document. Until now, the REJA24 system was based on a much simpler mechanism: a vessel was either entered in the register or deleted from it. The amendment introduces an intermediate solution, allowing the administration to respond to a failure to update data or other irregularities without having to immediately remove the vessel from the register.  

Suspension will take place, amongst other things:  

• in the event of a failure to fulfil the obligation to update data, 
• where discrepancies are found between the information contained in the register and the actual situation, 
• in connection with a breach of obligations arising from maritime safety regulations.  

It is worth bearing in mind that the suspension will not merely be an administrative procedure recorded in the system. The draft provides for a ban on sailing and operating the vessel whilst the document is suspended. This means that a ship operator who fails to comply with the obligation to update their details may effectively be prevented from using the vessel legally until the details in the register have been brought up to date.  

Deletion from the register as a last resort  

The amendment significantly expands the list of circumstances leading to the removal of a vessel from the register. This primarily concerns:  

• failure to update data, 
• failure to fulfil obligations following the suspension of a document, 
• failure to respond to requests from administrative authorities or authorised organisations, 
• certain cases relating to maritime safety.  

In practice, this marks a further departure from the philosophy that underpinned the creation of REJA24. For years, the Polish flag was seen as a simple, stable and virtually maintenance-free solution. The proposed regulations provide for a more active relationship between the ship operator and the register, through regular confirmation that the data is up to date.  

For most ship operators, this should not be a problem. An owner who keeps their details up to date and responds to correspondence from the authorities is unlikely ever to face suspension or deregistration proceedings. This does not alter the fact that the new obligations will also apply to owners who obtained Polish registration under entirely different legal circumstances, based on documents valid indefinitely and minimal contact with the register.  

In my view, the direction of these changes is reasonable. The flag state should have up-to-date information on vessels flying its flag and effective means of verifying that information.  

However, the final assessment of the reform will depend on whether the new obligations remain proportionate and do not become a source of excessive costs or red tape for ship operators who have placed their trust in the Polish registration system as it currently stands.  

Standardisation of HIN, WIN and INI numbers  

One of the less publicised but highly practical changes is the clarification of the rules for identifying vessels. The draft moves away from an approach focused solely on numbers assigned in accordance with the European HIN, CIN and WIN standards, allowing other identification numbers with which the hull has been marked by the manufacturer to be disclosed in the register.  

This is of particular significance for vessels from outside the European Union. The draft’s justification explicitly states that the aim of the amendment is to enable the register to include numbers assigned by manufacturers operating outside the system of standards set out in the EU Recreational Craft Directive, including, amongst others, US manufacturers. This solution responds to the requests put forward by the ship operators’ community and the insurance market.  

The amendment also clarifies the rules for assigning an individual identification number (INI). If a vessel does not have an identification number within the meaning of the Act, the registering authority will assign it an INI, which must be permanently affixed to the hull. The draft provides that the existing manufacturer’s marking will not be removed or replaced. In the case of vessels with an identification number other than HIN, CIN or WIN, the new INI number is to be affixed in the immediate vicinity of the existing marking, whilst ensuring that the latter remains visible. This means that both numbers will co-exist on the hull and in the registration documentation.  

Although these changes are of a technical nature, in practice they may make it easier to identify vessels, organise documentation and reduce some of the problems that arise in connection with registrations, changes of ownership, insurance or the verification of a vessel’s history.  

Ship operator’s data subject to greater administrative oversight  

One of the less noticeable consequences of the amendment is a significant expansion of the scope of data collected by the register. At present, many ship operators view REJA24 primarily as a tool for confirming a vessel’s ownership. The proposed regulations, however, aim to create a database enabling the authorities to maintain ongoing contact with the vessel’s owner or operator.  

In practice, this means an obligation to provide a greater amount of identifying information, including, amongst other things, nationality, details of co-owners’ shares in the vessel’s ownership, and, in certain cases, the ship operator’s email address and telephone number. The obligation to update this information whilst the vessel is in service will also be extended.  

From the administration’s point of view, this is one of the fundamental principles underpinning the entire reform. The Ministry has repeatedly emphasised that one of the problems with the current system is the lack of an effective means of contacting some ship operators who operate vessels outside Poland’s borders. The new regulations are intended to remedy this situation.  

For a foreign ship operator, this primarily means the need to manage their presence in the register more actively. At the same time, it can also bring tangible benefits. Up-to-date contact details and better organised ownership documentation enhance the security of the vessel’s trade, facilitate the processing of changes in ownership and reduce the risk of problems relating to the identification of the ship operator by the administration or financial institutions.  

We invite you to read the next article now – The Polish recreational flag following the amendment. Key changes to REJA24, Part 2 – in which I discuss, among other things, the initial survey, one of the most significant proposed changes.

Have you recently become the owner of a yacht and are wondering which flag would be the best choice for you? You have probably searched most of the Internet looking for an answer. In most cases, the answer is simple: the Polish flag is currently the best option. Why? A straightforward and quick registration procedure, low costs and no additional requirements such as a technical survey.

So, what does the yacht registration procedure in Poland look like?

The Polish register of yachts and other vessels of up to 24 metres in length is maintained through the REJA24 system. An application may be submitted to any chosen registration authority. There is no requirement to apply to the authority competent for the owner’s place of residence. This is particularly advantageous because authorities located in the northern parts of Poland tend to have considerably more experience in registering vessels than, for example, authorities in south-eastern Poland. The registration application may be submitted either in paper form or electronically.

What documents are required to register a yacht in Poland

Before starting the procedure, we will ask you to provide us with scans of the following documents:

  1. the yacht’s CE Declaration of Conformity – as a general rule, it should be submitted with the application if one was issued. This applies to vessels built after June 1998. If more than 10 years have passed since the CE Declaration was issued, or if the declaration has been lost and obtaining a duplicate is impossible, an appropriate declaration by the owner will be required. The absence of a CE Declaration does, however, have certain consequences: in particular, it will not be possible to confirm on this basis the vessel’s design category, the maximum number of persons permitted on board, the permissible wind force or significant wave height.

  2. a clear photograph of the builder’s plate (CE plate) – only if the vessel has a CE Declaration of Conformity. The plate is not formally required, but it may sometimes be used to confirm the maximum number of persons permitted on board. This is particularly relevant where the CE Declaration does not contain this information, which is relatively common.

  3. a photograph of the HIN, CIN or WIN – the identification number must comply with the relevant ISO standard and correspond to the number shown in the vessel’s documentation. If the yacht does not have an identification number, or if the existing marking does not comply with the ISO standard, the registration authority will assign a Polish Individual Identification Number (INI). The INI remains assigned to the vessel throughout its lifetime.

  4. a document confirming the engine power – this may, in particular, be an owner’s manual, warranty document, technical specification or manufacturer’s brochure. The most important point is that the document states the engine power in kW or HP and identifies the engine manufacturer.

  5. a photograph of the engine serial number, together with information indicating whether the engine is inboard or outboard and whether it is petrol or diesel. As a general rule, providing the engine serial number is optional, although in practice yacht owners usually choose to disclose it. A photograph of the engine plate may also help to decipher the serial number, which is often difficult to read in older documents.

  6. a document confirming ownership of the yacht – most commonly, this will be a bill of sale. In the case of a new vessel, it will usually be a VAT invoice. Polish law also recognises other forms of proof of ownership, such as a deed of gift, an exchange agreement or a certificate of inheritance. In the case of a self-built vessel, an appropriate declaration by the builder is required.

  7. confirmation of deletion from the previous register, if the yacht was previously registered abroad. The document should confirm both the date on which the previous registration ended and the fact that the vessel has been deleted from that register.

  8. an identity document for each owner – an identity card or passport.

  9. documents concerning the operator – if the yacht has two or more owners, they must appoint an operator from among themselves. The operator may also be a third party who is not an owner of the yacht. In such a case, we will prepare an appropriate declaration for you, to be signed by each owner, identifying the person or entity acting as the operator.

  10. a power of attorney authorising us to act on your behalf. We prepare this document individually for each case; all you need to do is sign it.

What information do we need before submitting the application

In addition to the documents themselves, we will need to agree with you on several basic matters concerning the intended use of the vessel.

First of all, we need the name of the yacht. The regulations impose certain basic restrictions in this respect – the name must not be contrary to accepted standards of decency or be misleadingly similar to designations used by rescue services. Importantly, due to the way the REJA24 system operates, the name you choose does not need to be unique and may be used by other vessels as well. In many foreign registers, as well as in the Polish permanent ship register, a vessel’s name must be unique.

In the case of a seagoing yacht, a Polish maritime port of registry must be specified. Foreign owners most commonly choose Gdańsk, Gdynia or Sopot, i.e. ports within the Tricity metropolitan area.

It is also necessary to determine whether the yacht will be used for recreational or commercial purposes. This is an important decision. Commercial operation involves additional requirements concerning, among other things, vessel safety and documentation. The registration and operation of commercial yachts requires separate discussion and will be covered in our future publications.

The final basic piece of information is the area of operation. We need to specify whether the vessel will be used on maritime waters, inland waters, or both. Even if you select both areas of operation, the registration document will display the same designation as for maritime waters alone, namely “M”.

Foreign documents and translations

A significant proportion of the registrations we handle concern yachts purchased abroad. This means that most of the relevant documents are in a foreign language. As a result, certified translations will need to be submitted with the application. The documents that most commonly require certified translation are the bill of sale, engine documentation and the certificate confirming deletion from the previous register.

One important practical advantage is that registration authorities will usually not require a translation of the entire document, for example a lengthy bill of sale. In practice, it is often sufficient to translate only the relevant sections identifying the buyer, seller, vessel details and formal elements such as signatures.

What does the yacht registration procedure involve

Once we receive your documents, our first task will be to review them. In particular, we will verify the yacht’s details, its HIN/CIN/WIN and whether the identification number corresponds with the CE Declaration and the other documentation.

Once the documents have been reviewed, we will prepare a power of attorney for you, together with any additional declarations that may be required for the registration of your vessel or may help speed up the process.

We will then submit the application to the registration authority, which will verify the completeness and correctness of the documents provided. Once they have been reviewed, the authority issues a certificate confirming the yacht’s registration. In practice, where the application has been properly prepared, obtaining such a certificate usually takes approximately 3 to 7 working days.

The owner may use the certificate until the final registration document is issued. This means that once you have received the certificate, you can already sail the yacht. As a precaution, however, we always recommend keeping a copy of the bill of sale or VAT invoice on board together with the certificate. This is important because the certificate contains only the yacht’s details – it does not state the name of the owner, whether an individual or a legal entity. Obtaining the physical registration document usually takes around two weeks.

How much does it cost to register a yacht in Poland

At present, the administrative fee for processing a yacht registration application is PLN 80. The official costs may also include the cost of certified translations, as well as the representative’s professional fees for handling the registration procedure and the administrative fee applicable to the power of attorney.

Changes to the Yacht Registration Act

The current rules governing yacht registration may change in the near future. Work is currently under way on an amendment to the legislation intended to increase control over vessels registered under the Polish flag, introduce periodic confirmation of the validity of registration documents and increase registration fees, particularly for foreign owners. For the time being, however, these are only proposals currently being discussed by a parliamentary committee. Much will depend on whether the legislation ultimately receives the support of both the Sejm and the Senate and is subsequently signed by the President of Poland.

We will discuss the proposed changes and their significance for foreign owners of yachts registered in Poland in our next article.

Finally, we would like to invite you to read our free e-book, Safe Yacht Purchase 3.0. It contains plenty of valuable information and practical guidance that may be useful to you when buying or selling a yacht.