Share transfer restrictions in shareholders’ agreements

27 January 2023 | Knowledge, News

The imposition of restrictions on the transferability of shares and the introduction of relevant related procedures are among the most important issues to be negotiated prior to the conclusion of shareholders’ agreements.

The following is an overview of the most common types of clauses restricting the ability to dispose of company shares.

Consent to disposal

Shareholders’ agreements often contain provisions making the disposal of shares subject to a company’s consent or other restriction (similarly to solutions that can be introduced into the articles of association, in accordance with relevant provisions of the Commercial Companies Code).

Consent to the disposal of shares, which must be given by the company management board, is the most common of these. However, the following entities are often indicated as authorised to give such consent:

  • another body (e.g. the supervisory board or the general meeting),
  • a majority shareholder,
  • a third party.

The right of first offer and the right of first refusal

Both the right of first offer (Polish: prawo pierwokupu) and the right of first refusal (Polish:  prawo pierwszeństwa) contained in a shareholders’ agreement entitle the entity concerned to acquire the shares of another shareholder if the latter intends to sell them to a third party.

Importantly, the right of first refusal is broader than the right of first offer, since it applies to any sale of shares and not only to a sale under a conditional SPA.

Drag-along and tag-along clauses

Drag-along clauses are becoming increasingly common in the Polish market. Thanks to their introduction, in the event of a desire to sell shares to a potential external investor, who is often interested in acquiring 100% of the shares, a person who has reached an agreement with the investor on the disposal of his/her own assets may require the other shareholders to sell their shares on analogous terms and conditions.

A tag-along clause is a kind of a reverse mechanism that allows shareholders to require the one who has attracted an external investor to cause that investor to make an offer for acquiring their shares on identical terms and conditions.

Call option

A call option grants the right for a potential buyer to demand a particular transaction to be performed.

If the call option is exercised, the buyer will be able to purchase shares from their seller at a specific price and time, with the latter being obliged to transfer the shares to the buyer on request or upon the fulfilment of certain conditions indicated in the agreement.

Lock-up

Lock-up clauses in shareholders’ agreements prevent certain shareholders from disposing of their shares for a specific period of time.

The purpose of such clauses is to obtain a guarantee by an investor that a particular person will remain in a company for a certain period of time. Most often, such a clause applies to company founders or key employees who also hold shares in the company.

Summary

Share transfer restrictions in shareholders’ agreements are a solution that effectively safeguards the interests of shareholders.

If such restrictions are imposed, however, due care must be taken to ensure that they function properly.

 

Source: Rzeczpospolita

Date: 22.12.2022

Any questions? Contact us

Rafał Rapala

Dominik Karkoszka

Adam Czarnota

 

Latest Knowledge

Banking sector overview | Banking today and tomorrow | July 2026

Under the draft legislation, banks will be required to offer existing borrowers a switch from WIBOR-based to POLSTR-based interest rates, a mechanism intended to speed up the voluntary transition of financial instruments to the new benchmark. The banking sector has responded positively to the proposal, according to Tadeusz Białek, President of the Polish Bank Association.

“Withdraw from contract here” – what next for the new button in online shops, on trading platforms and in mobile apps?

From 19 June, national legislation was to require businesses in the European Union entering into distance contracts with consumers via an online interface to provide consumers with the option to withdraw from the contract via a dedicated function/button. However, due to Poland’s delay in transposing Directive 2023/2673, which requires the use of such a button, this obligation has been postponed in our country. We look at what remote contract withdrawal entails and which transactions the new feature will apply to.

Municipal master plans – new deadline, same old challenges

On 11 June 2026, the President signed into law a bill extending the deadline for municipalities to adopt their master plans (plany ogólne). The key deadline for adopting master plans was moved from 30 June to 31 August 2026. We examine the reasons behind this change and consider what the absence of a master plan might mean for potential investors and their future projects.

Record fines and the upcoming 21st sanctions package – what should businesses expect?

The past year has brought a series of enforcement actions that clearly signal a tightening approach by the Polish customs and revenue authorities towards breaches of the sanctions regime. Importantly, businesses should already be preparing for further changes, as the European Union has announced its 21st sanctions package and updated the list of designated persons and entities. We examine the key developments and offer guidance on how to minimise the risk of non-compliance.

A sea change in the rules governing board members’ liability for a company’s tax arrears

The bill amending the General Tax Code (No. UC138) fundamentally overhauls the rules governing the tax liability of third parties for capital companies’ tax arrears.  It comes in response to recent CJEU judgments, the Ombudsman’s February statement and the post-audit report of the Supreme Chamber of Audit (NIK) of December 2025. We examine what’s changing, who will be affected by the new rules and what steps are worth taking right now.

Partner in name, but only if male: the linguistic trap in Polish corporate law

One of the structures available under Polish law is the ‘spółka partnerska’ (professional partnership), modelled on the Anglo-Saxon Limited Liability Partnership. As defined in the Polish Commercial Companies Code, this is a vehicle for individuals practising liberal professions, such as doctors, architects and accountants. And yet, the provisions governing professional partnerships make no mention of their applicability to women. We therefore examine whether there is no room for female partners, feminine-gendered forms, or simply linguistic empathy.

Can you sue over words aimed at an entire community?

A damaging public statement does not necessarily refer to a specific individual. Sometimes, the author attributes negative characteristics to a whole group of people, portrays them as a threat or uses language that could be seen as demeaning. Statements of this kind frequently concern LGBTQ+ people. This raises the question: can a member of the targeted community bring a lawsuit seeking compensation or an apology, even if they were not named directly? We decided to look into this.

Banking sector overview | Banking today and tomorrow | June 2026

According to a statement published by GPW Benchmark, the reference rate administrator, and the Polish Financial Supervision Authority (KNF), which oversees the administrator, 31 December 2036 will be the last day on which the WIBID and WIBOR rates will be provided for all key fixing periods: 1 month (1M), 3 months (3M) and 6 months (6M).

How to correctly calculate length of service from 1 May 2026

New rules for calculating length of service have applied to private sector employers since the beginning of May 2026. With companies continuing to express concerns about the new framework, the Ministry of Family, Labour and Social Policy has addressed the most common questions. We look at the issues that are (still) troubling employers and how we can help.

Contact us:

Rafał Rapala

Rafał Rapala

Attorney-at-law / Partner / Head of Corporate Law and Corporate Litigation / M&A, Private Equity

+48 608 444 650

r.rapala@kochanski.pl

Adam Czarnota

Adam Czarnota

Advocate / Senior Associate / Corporate Law / Mergers & Acquisitions

+48 787 389 207

a.czarnota@kochanski.pl