Freight Forwarding in Poland: No Carrier's Licence, but a Licence of Its Own
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 drops most of them? There is one — but, as explained below, it is not licence-free.
Forwarding needs no carrier’s licence
In Poland, freight forwarding (spedycja) does not require a carrier’s 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 out almost all of it:
- Operating base and parking spaces — not required
- The carrier’s per-vehicle financial standing (€9,000 for the first vehicle, €5,000 for each further one) — not required
- A certificate of professional competence (CPC) — still required (see below)
- Operator authorisation, Community licence, a certified copy per vehicle — not required
- Vehicles, drivers, tachographs, e-TOLL — not required
One item stays on the list — the CPC — and forwarding adds a licence of its own.
The licence forwarding does need
A company that organises the carriage of goods for others without carrying them itself needs the licence for intermediation in the carriage of goods — licencja na wykonywanie transportu drogowego w zakresie pośrednictwa przy przewozie rzeczy, commonly called the licencja spedycyjna (forwarding licence). As the government portal biznes.gov.pl puts it, the licence lets your company organise carriage for others, but not carry goods itself.
The conditions:
- Good repute — the people managing the company have no final convictions for the offences listed in Poland’s Road Transport Act
- Professional competence — at least one person managing the company, or the person managing road transport in it, holds a certificate of professional competence (certyfikat kompetencji zawodowych)
- Financial standing of €50,000 — funds or assets at the company’s disposal, shown for example by a bank statement, a bank guarantee or the annual financial statement
The licence is issued by the starosta (county office) for the company’s registered office — not by GITD. The official fee depends on the validity period you apply for: 800 PLN for 2–15 years, 900 PLN for 15–30 years, 1,000 PLN for 30–50 years. The decision should take no longer than a month, extendable to two.
Note that €50,000 is more than the €9,000 a one-truck carrier has to show. What makes forwarding the lighter entry is everything else: no base, no vehicles, no drivers, no fleet to finance.
Beyond the licence, 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 carrier’s 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 which licence you need.
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, obtain the forwarding licence and start trading as a forwarder — no fleet to finance
- 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, the carrier’s financial standing and the carrier’s licence, and move to your own fleet
The entry point is lighter than a carrier’s, but not free: the forwarding licence comes first, with its CPC and €50,000 requirements — and when you add the carrier’s licence, a CPC holder is already in the company.
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 needs no capital for vehicles, 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 the €50,000 financial standing and 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, preparing the application for the forwarding licence, 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. Your company files the application and the starosta decides on it; we prepare the file and advise on meeting the CPC and €50,000 conditions.
When you later want to move into haulage as a carrier, we prepare the carrier’s licence file — base, financial standing, application — 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?
- Not the carrier's licence — but forwarding needs a licence of its own. A company that organises carriage for others without carrying goods itself needs the licence for intermediation in the carriage of goods (licencja spedycyjna), issued by the starosta for its registered office. It requires good repute, a certificate of professional competence held by someone managing the company or its road transport, and €50,000 of financial standing; the official fee is 800–1,000 PLN depending on the validity period. No operating base, operator authorisation, Community licence or vehicles are needed.
- 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 carrier's licence later?
- Yes, and in practice this is the most sensible sequence. The forwarding business needs its own licence first, but it 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. The carrier's licence is then added to the same company.
- Is the capital requirement for forwarding genuinely low?
- Usually lower than a carrier's, because there is no fleet to finance — but not low. The forwarding licence requires €50,000 of financial standing, more than the €9,000 a one-truck carrier shows. And 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.