Changes in transport regulations — what will ITD check?
In 2024, the Road Transport Inspection changed its priorities during roadside checks and those conducted at company headquarters. New administrative penalty rates mean that even a small oversight in digital files can cost a carrier from 1,200 to 12,000 PLN. Sarmatia Risk Control explains what to look for so that an official finds no basis to initiate proceedings.
New tariff and penalties for lack of country entries
Since March 2024, ITD inspectors across the Lublin voivodeship have emphasized the obligation to enter the country symbol after crossing the border. If your driver forgets this entry, the penalty is 100 PLN for each day, but it accumulates during a roadside check covering the last 28 days. In practice, we have seen protocols where the sum of penalties for just missing border entries exceeded 2,800 PLN for one employee. This is not theory — in May 2024, we helped a company from Lublin that received a 14,300 PLN fine exactly for the accumulation of such small errors across three drivers.
It is worth remembering that these errors hit not only the wallet but also the carrier's good reputation. According to the Road Transport Act, multiple violations in the MS category (most serious violations) can lead to the withdrawal of a license. Currently, offices don't wait for explanations; they automatically send a notification to the KREPTD register. Peace in the company depends on whether your drivers know that every second of stopping at the border must be recorded in the tacho. The end of stress with inspections starts where ignoring manual entry procedures ends.
Analyzing 47 inspections from the last quarter, we noticed that ITD is increasingly using DSRC remote tachograph reading devices. An inspector no longer has to stop a truck in a parking lot to know if a driver card is inserted in the slot. If the system detects driving without a card, the chances of avoiding a 2,000 PLN fine drop to zero. At Sarmatia Risk Control, we recommend verifying logins every 14 days, not every 28 as the law says. This gives time to react and potentially correct errors before the inspection arrives at the base.
An error in a single .ddd file can generate a penalty of 2,400 PLN imposed directly on the transport manager.
Exchanging tachographs for Smart 2.0 — critical deadlines
For companies performing international transport, 2024 is a time of forced investment in equipment. By December 31, 2024, all vehicles equipped with analog tachographs and first-generation digital ones must have Smart 2.0 devices. The cost of replacement in one car is approximately 3,800 PLN net, which for a fleet of 9 vehicles means an expense of around 34,200 PLN within a few months. This is a huge burden for small businesses, but a lack of modernization after January 1, 2025, excludes the car from traffic outside Poland.
New tachographs automatically record border crossings using GNSS signals, which theoretically relieves the driver but generates new challenges for administration. These systems are more sensitive to GPS signal interference. If the device loses coverage for more than 18 minutes while driving, the tacho will record an error that will be treated as an attempted fraud during checks in Germany or France. A concrete defense against such accusations requires having reports from the tacho service that confirm the efficiency of the GNSS antenna in your vehicle.
At Sarmatia Risk Control, we checked that nearly 23% of transport companies in the region are still delaying the installation of new readers. Service centers in Lublin and the surrounding area already have appointments booked 3-4 weeks in advance. If you don't reserve a slot in a workshop by the end of October 2024, you risk grounding the fleet during the busiest pre-Christmas period. Offices don't wait for your explanations about lack of parts — the law is ruthless and enforced immediately by road services throughout Europe.
Driver documentation in the IMI system
Posting drivers is currently the second most common reason for penalties imposed by ITD and the National Labour Inspectorate. Since the introduction of the Mobility Package, every driver on cross-trade or cabotage must be registered in the IMI system. Lack of a current registration is a fine of 500 PLN for every day of work abroad. During one of our interventions in July 2024, we saved a carrier from an 11,200 PLN fine by demonstrating errors in the office's IT system, which had not refreshed driver data.
Inspectors require that payroll documentation (payslips, transfer confirmations) be available upon every request within 48 hours of a query sent via the IMI portal. If your accounting works slowly and does not provide documents within this deadline, the system automatically flags the company for a full tax audit. This is a situation we want to avoid at all costs. Sarmatia Risk Control helps implement a digital archive that allows you to send a set of 14 documents with one click, without stress and searching for papers in binders.
It is also crucial to have an employment contract translated into English or the language of the country where the driver performs transport operations. Although Polish regulations do not explicitly require this in every case, French or Belgian services can impose a deposit of 750 EUR towards a future fine in the absence of a translation. Peace in the company is ensured only by a complete driver file that is updated at least once a month by a dedicated employee or an external auditor.
Offices don't wait for your explanations about accounting delays — 48 hours is a rigid deadline.
How to behave during a roadside check?
The way a driver speaks to an ITD inspector has a direct impact on the amount of the fine. The driver should know that they have the right to add remarks to the inspection protocol. If the tacho indicated a violation that resulted from a lack of parking space, the driver must describe it on a printout from the tachograph immediately after the event occurred, citing Article 12 of Regulation 561/2006. Without such a description, an appeal against the fine is ineffective in 95.8% of cases.
During a roadside check, the inspector also checks the technical condition. In 2023, 14% more registration certificates were seized in Poland for fluid leaks and brake system defects than the year before. Penalties for poor technical condition can reach 2,000 PLN per vehicle, and in extreme cases lead to a ban on further driving. This means transshipment and towing costs, which often exceed 4,500 PLN. Peace in the company is built through daily vehicle inspection logs that the driver must sign before leaving the base.
At Sarmatia Risk Control, we teach drivers how to use the 'OUT' function and how to document weekly rests outside the cabin. Since 2022, there has been a ban on sleeping in the cabin during regular 45-hour rests. Inspectors in Belgium check hotels and invoices from the last 2 weeks. If the driver has no proof of hotel accommodation, the fine is about 1,800 EUR. Having personal invoices made out to the company is the only concrete defense that allows avoiding a bank account block for the carrier by foreign services.
Internal audit — the only way to peace
The carrier's worst mistake is waiting for a letter from the office about starting an inspection. At Sarmatia Risk Control, we conduct audits that simulate an ITD visit. We review the last 156 days of driver work and point out where penalties might occur. Such an audit costs a fraction of what one fine for lack of data continuity in digital files costs. In March 2024, we detected an error in a reader in a Lublin-based company that incorrectly recorded dates — thanks to a quick reaction, the company avoided an estimated fine of 8,400 PLN.
An audit is not just about checking the tacho; it's also about verifying the validity of medical and psychotechnical tests as well as ADR qualifications. Lack of a valid medical test for a driver during a PIP inspection at the company headquarters is a 1,000 PLN fine per person. With a team of 7 people, overlooking deadlines can cost 7,000 PLN. Offices don't wait for you to remember about the tests — they come and check the dates. The end of stress with inspections is only possible when you have a reminder system and keep documentation in an orderly manner.
Remember that you have 14 days from an ITD decision to file an appeal with the Chief Inspector of Road Transport. The effectiveness of appeals increases by 31% if they are supported by concrete evidence from GPS systems or base monitoring recordings. We at Sarmatia Risk Control prepare such letters based on the current case law of administrative courts. We have been operating since 2017 and know that an official can also make a mistake. Concrete defense of your assets is our priority. Schedule a 20-minute documentation audit to check if your company is safe.
