The Central Contract Register in local government, step by step: who reports, within what deadline, and how to avoid doing it manually

The register has been operating for three months, and the first contracts have already passed their entry deadline. This is a good moment to check whether the obligation is properly organised in the office, or merely "handled somehow". An entry does not replace legal advice.

Where this obligation comes from and when it takes effect

The legal basis is Articles 34a, 34b and 34d of the Public Finance Act, together with the Regulation of the Minister of Finance and the Economy of 30 March 2026 (Journal of Laws of 2026, item 440). The full name is the Central Register of Contracts of Public Finance Sector Entities (Centralny Rejestr Umów Jednostek Sektora Finansów Publicznych), abbreviated CRU JSFP.

The register has been postponed several times: the 2021 Act set a launch date of 1 July 2022, which was then pushed back to 1 January 2024, and again to 1 January 2026. The Act of 4 December 2025 (Journal of Laws of 2025, item 1844) rewrote the provisions and introduced them in two steps: from 1 April 2026, entities set up accounts, and from 1 July 2026, they publish information on contracts. The obligation applies to contracts concluded from 1 July 2026 onwards.

This is worth knowing, because many offices still have information in circulation from the earlier version of the rules: a value threshold, a 14-day deadline and a penal provision. None of these three things appear in the version currently in force.

Who reports

The obligation rests with the head of the public finance sector entity. This covers entities listed in Article 9 of the Act, which in local government include, among others, the gmina (municipality), the powiat (district), budgetary units, budgetary establishments and cultural institutions. A contract concluded by an authority, such as the wójt (head of the municipality) or the district board, is entered by the head of the entity that services that authority. Commercial-law companies, including municipal companies (spółki komunalne), do not belong to the public finance sector and, according to explanations from the Ministry of Finance, the register does not apply to them.

Three points from the ministry's explanations have practical significance for local government:

An account is set up for each REGON number (the Polish business-registry number). The gmina and the municipal office, or the powiat and the starostwo (district office), may each have separate accounts. If only one of these entities concludes contracts, one account is enough.
The contract is entered by the entity it concerns. Entering it under another entity's account is treated by the ministry as a failure to perform the obligation.
A shared services centre does not take over the obligation. The account application is submitted by the head of the given entity or their representative. The regulation allows one person to hold access rights to several entities' accounts, each on the basis of a separate application.

The head of the entity does not have to do the clicking personally. The system has three types of access rights: administrator, data entry and publisher. The ministry recommends a two-pairs-of-eyes principle: one person enters the data, another checks and publishes it. Login is personal, via Profil Zaufany (Trusted Profile), mObywatel or another means from the national identification node.

Which contracts, and within what deadline

A contract is entered in the register if it meets two conditions jointly: it is a procurement within the meaning of the Public Procurement Law, i.e. a paid contract for supplies, services or construction works, and it was concluded in written, documentary, electronic or another special form.

There is no value threshold. The ministry states explicitly that the obligation potentially covers contracts "from a single grosz" and does not depend on whether public-procurement procedures were applied. An invoice on its own is not a contract and is not subject to entry. Nor are oral contracts, although the head of the entity may choose to enter them voluntarily.

Outside the register are, among others, employment-law contracts, contracts in the field of defence and security, and healthcare-service contracts published by the NFZ (National Health Fund). According to the ministry's explanations, grant agreements are not procurements. Information whose disclosure is restricted under the public-access-to-information rules is not published, but in that case the legal basis and the person who made that decision must be indicated.

Scope of the entry: contract number, date of conclusion, duration, parties, subject matter, net value including options and renewals (for an indefinite-term contract, covering the first 48 months), information on EU funding, and status.

Deadline: without undue delay, no later than 30 days from the conclusion of the contract. The same period applies to updates following an amendment, termination, assignment or the discovery of an error. Amendments to contracts concluded before 1 July 2026 are not entered, but an execution order with a new date issued under an older framework agreement is.

For financial oversight

The provisions on the register, as currently worded, do not provide for a separate sanction for a late or incorrect entry. The penal provision from the original 2021 version never entered into force. That does not mean there is no risk. The register is public, so a missing contract is visible to anyone: a council member, a journalist, an auditor. According to the ministry, the head of the entity is responsible for ensuring that entries match the actual and legal state of affairs. They are also the data controller, and so responsible for not publishing personal data beyond what is necessary. How to assess a specific failure should be a question for the office's own legal counsel.

Form or interface

The system is free of charge. Staff of entities log in at jsfp.rejestrumow.gov.pl, while the public preview is available at rejestrumow.gov.pl.

There are two ways of feeding data in. The first is a browser-based form. The second is an application programming interface (API), provided for in the regulation and described on the ministry's website: it allows contracts to be published and updated, withdrawn, and published data retrieved. The ministry also provides a test environment.

Whether your system uses this interface is a question to put to your supplier directly: does it work already today, under your current contract, or only for an additional fee.

The chain: invoice, case, contract, register, accounting

The register is not a separate task; it is a link in a workflow that the office runs anyway.

The contract is created within a case handled in an EZD-class system (electronic document and case management system). The skarbnik (treasurer) adds a countersignature, and the commitment is recorded in the financial and accounting system. Then an invoice arrives from KSeF (the Polish National e-Invoicing System), which must be linked to the contract and described. The register needs data from the very beginning of this chain: the parties, the subject matter, the value, the dates.

Analogy

It is like writing the same data into four separate notebooks: in the department, in accounting, in the office's own contract register, and in the central register. Every re-entry is an opportunity for a mistake. Automation is not about buying a fifth notebook; it is about deciding which one comes first.

A typical difficulty: contracts are signed by departments, the contract register is kept by someone in a spreadsheet, and accounting only finds out about a contract when the first invoice arrives. In that case, the 30-day deadline passes unnoticed, and small orders confirmed by e-mail are the ones most easily missed.

What to check in your office this week

Accounts. Whether the office and every organisational unit with its own REGON number have an account and a full set of access rights, including cover arrangements for holidays.
Owner. Who is responsible for the completeness of entries. It works best to use a unit that already sees every contract anyway, for example the one that keeps the office's contract register, under the supervision of the sekretarz (secretary) and in cooperation with the skarbnik (treasurer). Put this in writing in an internal order.
Source. Where the contract is given its number, and from which point you count the 30 days.
Small orders. How orders below the public-procurement threshold, placed by e-mail or on an order form, make their way into the register.
Changes. Who reports an amendment, a termination and the end of a contract.
Disclosure. Who decides to withhold information and checks personal data before publication.
Checks. A monthly comparison of the report from the entity's account against the list of contracts from accounting.
Systems. A question to the suppliers of the document-workflow system and the financial-accounting system about support for the register's interface.

Points 1 to 7 do not require any purchase. How to fit them into a broader plan is something I write about in the post on a strategy that doesn't end up in a drawer.

Sources

Legal status as at 4 October 2026.