Haulage Without a Licence: Setting Up a Freight Forwarding Company in Poland
The obstacles described in the earlier articles are real: the operating base, €9,000 of financial standing, a transport manager holding a CPC, licence fees, vehicles. Together they mean months and serious capital.
What if there were a route that requires none of them?
Forwarding needs no transport licence
In Poland, freight forwarding (spedycja) does not require a transport licence. The reason is simple: a forwarder does not perform the carriage — they organise it.
The legal basis is Articles 794–804 of the Civil Code. Under a forwarding contract the forwarder undertakes, for remuneration and within the scope of their business, to dispatch or receive a consignment or to perform other services connected with its carriage.
The essence of the business is not moving goods but arranging their movement: selecting the carrier, agreeing the terms, preparing the documents, running the process.
What you no longer need
Take the list of requirements for becoming a carrier, and cross it out:
- Operating base and parking spaces — not required
- €9,000 of financial standing for the first vehicle — not required
- A transport manager with a CPC — not required
- Operator authorisation, Community licence, a certified copy per vehicle — not required
- Vehicles, drivers, tachographs, e-TOLL — not required
What remains are the ordinary requirements of any company: incorporating a sp. z o.o. (or a sole trader), VAT registration, accounting, and OCS — forwarder’s liability insurance.
The line you must not cross
Be careful here, because the distinction is drawn by what you actually do, not by what you call yourself.
If you carry with your own vehicle you are a carrier, and you need the licence. That much is obvious.
The subtler trap: if you contract in the capacity of a carrier, present yourself as the carrier on the CMR, or accept liability for the carriage as a carrier would, your activity can be classified as carriage — even with no vehicle of your own.
Forwarding and carriage are entirely separate contract types. The capacity in which you contract determines both your liability and whether you need a licence.
The difference in liability
This distinction also explains where the money sits.
A carrier is directly liable for the goods carried. A forwarder is liable principally for the care taken in selecting the carrier — where the selection was diligent, loss caused by the carrier’s fault is as a rule the carrier’s.
That is a lighter regime, but it is not an absence of liability. This is why forwarders take out OCS, forwarder’s liability insurance — a different product from the carrier’s OCP.
The strategic point
What was the new carrier’s biggest problem? That the freight exchanges are closed: Trans.eu wants 12 months of trading history, TimoCom 6. Leasing companies want the same thing.
Forwarding produces that history.
The sequence can be built like this:
- Incorporate and start trading as a forwarder — no capital barrier
- Build a customer base, turnover and documented trading history
- TimoCom opens at month six, Trans.eu at month twelve
- Meanwhile your financial statements accumulate — a leasing application is no longer an empty file
- When you are ready, add the base, financial standing and licence, and move to your own fleet
Instead of losing the first year, you spend it dismantling every obstacle that stood in the way of starting as a carrier.
A realistic warning: cash flow
Forwarding starts with little capital, but it is not easy on cash flow. You collect from the customer on 30–60 day terms while frequently having to pay the carrier sooner.
The capital barrier does not disappear — it moves from the vehicle to working capital. Margins are typically thin, and the business works on volume and on choosing carriers well.
What Meyis does
Incorporating the forwarding company, VAT registration, accounting, and getting the contract structure right — in particular making it unambiguous in the contract whether you are forwarding or carrying — sit on our side.
When you later want to move into licensed haulage, we add the base, financial standing and licence process on the same company. Building the structure for that transition from the start is far cheaper than correcting it afterwards.
Related reading
Frequently asked questions
- Do I need a transport licence for freight forwarding?
- No. A forwarder organises carriage rather than performing it, so no operator authorisation, Community licence or certified copies are required. Nor are an operating base, €9,000 of financial standing or a certificate of professional competence.
- What is the legal difference between forwarding and carriage?
- The forwarding contract is governed by Articles 794–804 of the Civil Code and covers dispatching or receiving a consignment, or other services connected with its carriage. A contract of carriage concerns physically moving the goods. They are separate contract types.
- When am I treated as a carrier?
- Certainly when you carry with your own vehicle. Beyond that, if you contract in the capacity of a carrier or present yourself as the carrier on the CMR, your activity can be classified as carriage even with no vehicle of your own.
- What insurance does a forwarder take out?
- OCS — forwarder's liability insurance. It is a different product from the carrier's OCP and covers the forwarder's own scope of liability.
- Can I start as a forwarder and add a licence later?
- Yes, and in practice this is the most sensible sequence. Forwarding produces exactly the trading history that freight exchanges and leasing companies require, and your financial statements build up while the doors open at months six and twelve.
- Is the capital requirement for forwarding genuinely low?
- The start-up capital is low, but the working capital requirement is high. You collect from customers on 30–60 day terms while usually paying carriers sooner, and margins are typically thin.